Epstein Secrets

n bond to secure any potential judgment that Jane Doe might obtain in this case. DATED this 19th day of June, 2009. 19 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

enue Suite 340 Coconut Grove, Florida 33133 [email protected] By: Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & AS SOCIA TES, LLC Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsim

e Lewis Tein, P.L. 3059 Grand A venue Suite 340 Coconut Grove, Florida 33133 [email protected] By: Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & AS SOCIA TES, LLC Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 T

t 06/19/2009 Page 10 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON The silence in the face of these questions speaks far louder than words. As Justice Brandeis recognized long ago, "[s]ilence is often evidence of the most persuasive character."' Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S.

S'S MOTION FOR FINAL SUMMARY JUDGMENT Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and pursu

for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the p

rt claims. The only cases not resolved are this case and two (2) cases in state court (all three Plaintiffs are represented by Plaintiff's counsel, Brad Edwards, Esq. and his firm). I 5. Plaintiffs in other filed cases were represented by various law firms as the court is aware. 6. With the additional disco

ity and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most persuasive character" from Epstein's repeated

ent's charges, this Court assured both adequate notice of the allegations against the defendants and ample opportunity for a meaningful de- fense. Edwards, 430 A.2d at 1339-41. 4. Even in full-blown criminal trials, the Sixth Amendments Confrontation Clause poses the only constitutional objection to

hey must be resolved in the crucible, f a live contro- versy (see Ashwander TVA, 297 U.S. 288, 346-47, 56 S.Ct. 466, 482-83, 80 L.Ed. 688 (1936) (Brandeis, J., concur- ring)), nothing in this opinion should be construed as either subscribing to or dis- avowing either Cirrincione or Hazzard. But as bot

m engaging in what was a blatant effort to extort Bradley Edwards, utilizing the nearly limitless resources of a ven

rity and Inv. Corp., 615 So.2d 841, 842 (Fla. 4" Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "evidence of the most persuasive character" from Epstein's repeated r