Epstein Secrets

in 4 session. The Honorable David Crow presiding. Miley Epstein, 5 MR. CRITTON: Good morning. Plaintiff. 6 MR. SCAROLA: Good morning, Judge. SCOTT ROTHSTEIN, individually, 7 THE WITNESS: Were here on Epstein versus BRADLEY J. EDWAFtDS, individually, and L.M. individually, Defendants. / 8 9 10 Ro

IN, individually, 7 THE WITNESS: Were here on Epstein versus BRADLEY J. EDWAFtDS, individually, and L.M. individually, Defendants. / 8 9 10 Rothstein, et al. So, I've read the materials you guys submitted on both sides and also read the counterclaim. HEARING BEFORE. THE HONORABLE 11 MR. SCAROL

here is no such allegation of a post-issuance 20 case first. 20 act other than service of what was issued under 21 They sued for malicious, Mr. Della-Donna 21 the circumstances. 22 sued for malicious prosecution, abuse of 22 And it goes on and describes abuse of 23 process, and liable. And at page

ired. It's part of the -- that is, it 12 fact and dispute. Furthermore Russell 13 doesn't go to the issue of the motion for 13 established that Della-Donna failed to allege 14 summary judgment. 14 and there was no evidence of any act by Russell 15 Secondly, there is no 772.11 claim in the 15 whic

ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the

brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al

Church of Scientology of Calif, Inc., 444 So.2d 442 (Fla. Dist. Ct. App. 1983) 18 Damiano v. Sony Music Entm 'I, Inc., 168 M. 485 (M. 1996) 27 Della-Donna v. Nova University, Inc., 512 So.2d 1051 (FIa. Dist. Ct. App. 1987) 18 DePalma v. DePalma, 538 So.2d 1290 (FIa. Dist. Ct. App. 1989) 21 E.I. Du

eme Action and does not Indeed, Epstein's settlement of the three suits legally km him from ever making such a claim for malicious prosecution. See Della-Donna v. Nova University, Inc., 512 So.2d 1051, 1055 (Fla. Dist. Ct. App. 1987) ("a bona fide termination favorable to plaintiff does not encompass a term

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM

FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14•• FLOOR. MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA00584348 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. Il. BACKGROUND In

. Payless Flea Mkt, 36 So. 3d 909, 917 (Fla. 411' DCA. 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n. 2 (Fla. 3d DCA 2006); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). With regard to the first element of the tort of abuse of process, it is axiomatic t

use Edwards' abuse of process claim is based on the filing of allegedly insufficient claims, it fails to state a valid claim for relief. See, e.g., Della-Donna, 512 So. 2d at 1055; McMurray, 425 So. 2d 1208 (counterclaim for abuse of process was properly dismissed with prejudice when based on filing of comp

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDA

FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14•• FLOOR. MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA00584338 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstcin's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. favor of Epstein on

. Payless Flea Mkt., 36 So. 3d 909, 917 (Fla. 4th DCA. 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n. 2 (Fla. 3d DCA 2006); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). With regard to the first element of the tort of abuse of process, it is axiomatic t

et al. abuse of process.' [Citation omitted] The plaintiff must prove improper use of process after it issues." S&I Invs., 36 So. 3d at 917(quoting Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055-56 (Fla. 411' DCA 1987)). See also Valdes, 924 So. 2d at 867 ("Valdes' failure to allege any improper wi

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein. Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fi

verted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 24 1051, 1055 (Fla. 4th DCA 1987). SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epstein states that

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/CO

ds must show that Epstein's filing of his abuse of process claim against him — which is the gravamen of Edwards' abuse of EFTA00582880 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Response in Opposition to Edwards' M/Dismiss Amended Complaint process claim against Epste

se of process requires proof that the judicial system was misused for an ulterior purpose after an action was filed and process served. See,. e.g., Della-Donna v. Nova University, Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987); McMurray v. U-Haul Co, Inc., 425 So. 2d 1208, 1209-10 (Fla. 4th DCA 1983). Acco

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein, Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fi

erted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt., Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). EFTA00292563 SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epst