Epstein Secrets

VISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, etc., et al., Defendant(s). ORDER ON COUNTER-PLAINTIFF EDWARDS' RENEWED MOTION FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES THIS CAUSE came before the Court upon the Counter-Plaintiff, BRADLEY J. EDWARDS' Mo

UNTER-PLAINTIFF EDWARDS' RENEWED MOTION FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES THIS CAUSE came before the Court upon the Counter-Plaintiff, BRADLEY J. EDWARDS' Motion to Amend to Add a Claim for Punitive Damages in regard to his abuse of process and malicious prosecution claims. The Court heard argument of

damages, the Plaintiff must make a showing through proffer of a "reasonable basis for recovery of such damages." See Fla. Stat. § 768.72. See also, Globe Newspaper Co. a King, 658 So.2d 518, 520 (Fla. 1995). While the burden is upon the party seeking punitive damages to make such an evidentiary proffer, the standa

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

r. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 28, 1996) 18 Bruno v. Stillman. Inc. v. Globe Newspaper Co. 633 F.2d 583 (1st Cir. 1980) 4, 5 Cablevision Systems Corp. v. DePalma, No. CV-87-3528 (JLC), 1989 WL 8165 (E.D.N.Y. Jan. 17. 1989) 7 Chick-Fil

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