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

ed long ago, "[s]ilence is often evidence of the most persuasive character."' Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

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

he most persuasive character."' Fraser v. Security 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

llion bond to secure any potential judgment that Jane Doe might obtain in this case. DATED this 19th day of June, 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre AC14 I OCfl And Paul G. Cassell Pro Hac Vice Ll 19 EFTA00234889 Case

venue Suite 340 Coconut Grove, Florida 33133 tein(alewistein.com Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 Paul G. Cassell Attorney for Plaintiff Pro Hac Vice EFTA00234902 D5/18O008 15:5$ FA)C,

ne, 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER

zed long ago, "[s]ilence is often evidence of the most persuasive character.'" Baxter v. Palmigiano, 425 U.S. 308, 319 (1976) (quoting U.S. ex rel. Bilokumsky v. Tod, 263 U.S. 149, 153-54 (1923)). This is plainly one of those situations. In a civil case, drawing an adverse inference is the proper action

Jane Doe #1 and Jane Doe #2. A proposed order to that effect is attached to this pleading. DATED: December 30, 2014 Respectfully Submitted, /s/ Bradley J. Edwardk Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LE RMA , P.L. And Paul G. Cassell Pro Hoc Vice S.J. Quinney College of Law at the

015, on all counsel or parties of record on the Service List below. /s/ Kendall Coffey SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, HSTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #I, 2, 3,

o sleazy, unprofessional. disbarrable lawyers, Paul Cassell, a former federal judge [and] current professor. and another sleazy lawyer from Florida. Brad Edwards — ... and said who would fit into this description: A lawyer, who knows Epstein, who helped draft ...? Ha, Dershowitzl So they and the woman got to

d be asked about Derhowitz's involvement took the Fifth." This "[sJilence is . . . evidence of the most persuasive character." United States ex rd. Bilokumsky 'Tod, 263 U.S. 149, 153-54 (1923) (Brandeis, J.). quoted in Baxter 1 Palmigiano, 425 U.S 308, 319 (1976). And that silence takes on an even more si

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

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

ed hereto as Exhibit “LL.” Edwards Pursues Other Lines of Discover 69. Because of Epstein’s thwarting of discovery and attacks on Edwards’s clients, Bdwards was forced to pursue other avenues of discovery. Edwards only pursued legitimate discovery designed to further the cases filed against Epstein. See E

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

f the most persuasive character.'" Fraser v. Security 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