Epstein Secrets

Florida, this day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT O

day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT OF THE FIFTEENTH JUD

is day of , 2009SAGOO et -, IREml VA r e `0 • David French' . Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., D EDWARDS, ESQ., Brad Edwards and Associates. , JAY HOWELL, ESQ., Jay Howell & Associates, PA, iterbuly Goldberger & Weiss. P.A. EFTA00722689 g e sz LEOPO

IRECTED TO PLAINTIFF'S COMPLAINT 1. Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982)

s O ) .1 •s--• tAtin Beach, it Our' c C•T David French Vr- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL, ESQ., Jay Howell & Associates, PA.. and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger EFTA0061441

, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL,

IRECTED TO PLAINTIFF'S COMPLAINT 1. Am. Home Assurance Co. v. Plaza Materials Corp., 908 So.2d 360, 374 (Fla. 2005) 2. Miami Herald Pub. Co. v. Ferre, 636 F.Supp. 970 (S.D. Fla. 1985) 3. Mantooth v. Richards, 557 So.2d 646 (Fla. 4th DCA 1990) 4. Lay v. Kremer, 411 So.2d 1347 (Fla. 1st DCA 1982)

RITTON: 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 Rothstein, et al. So, I've read the materials you guys submitted on both sides and

ins, RPR, FPR 22 judgment than it is a claim for a judgment on Notary Public, State of Florida 23 the pleadings. Prose Court Reporting 24 Mr. Edwards argues through his counsel Job No . 1783 25 that, in essence, Mr. Epstein's a bad person. Page 2 Page 4 APPEARANCES: 1. So no matter what hap

rt. 16 THE COURT: Right. 17 MR. SCAROLA: The case upon which we rely 18 is the Scozari case and the Miami Herald 19 Publishing Company versus Ferre case. They are 20 cited in our memo. And the holding in Scozari 21 that is instructive here is -- this is a Third 22 DCA case: If there was a r

ddress) LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED represented by Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1650 Ft. Lauderdale , FL 33301 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Paul

Entered: 06/08/2009) 06/08/2009 14k RESPONSE in Opposition re 144 Defendant's MOTION to Strike Cases from Current Trial Docket filed by Jane Doe. (Edwards, Bradley) (Entered: 06/08/2009) 06/08/2009 147 RESPONSE in Opposition re 104 Defendant's MOTION to Strike Cases from Current Trial Docket filed b

a civil remedy" (citing Villazonl. Prudential Health Care Plan, Inc., 843 So. 2d 842, 852 (Fla. 2003)). See also, e.g., Miami Herald Publ'g Co. 1. Ferre, 636 F. Supp. 970 (S.D. Fla. 1985) (King, (holding that violation of Florida's criminal extortion statute does not give rise to a civil cause of a

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

into taking some collateral action not properly involved in the proceeding a claim of abuse of process is stated. Miami Herald Publishing Company v. Ferre, 8636 F. Supp. 970 (S.D. Fla. 1985). In a case for abuse of process, the question of whether the plaintiffs case satisfies the requisite elements is

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes