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PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLE
TAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Counterclaim, alleging therein two causes of action against Epstein; abuse of process and mali
resolved in favor of the Defendant. This Steinberg case appears to be analogous to the Olson case upon which Edwards relied in his argument against Summary Judgment; an argument which was rejected by this Court. Transcript of Motion for Summary Judgment hearing, p. 58. The Olson case, just as this Court correct
ment in an action for abuse of process on the basis of absolute immunity and on the authority of Levin). As such, this Court was correct in granting Summary Judgment in 3 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613839 favor of Epstein. Edwards, despite his interminable filings,
PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA0408003OOOCMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RE
CONSIDERATION INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Counterclaim, alleging therein two causes of action against Epstein; abuse of process and mali
ment in an action for abuse of process on the basis of absolute immunity and on the authority of Levin). As such, this Court was correct in granting Summary Judgment in favor of Epstein. Edwards, despite his interminable filings, has not identified one Florida case decided either after the Wolfe decision or the
resolved in favor of the Defendant. This Steinberg case appears to be analogous to the Olson case upon which Edwards relied in his argument against Summary Judgment; an argument which was rejected by this Court. Transcript of Motion for Slummy Judgment hearing, p. 58. The Olson case, just as this Court correctl
CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, etc., et al., Defendant(s). ORDER ON DEFENDANT EDWARDS' MOTION FOR SUMMARY JUDGMENT THIS CAUSE came before the Court upon the Defendant, BRADLEY J. EDWARDS' Motion for Summary Judgment in regard to the
THSTEIN, etc., et al., Defendant(s). ORDER ON DEFENDANT EDWARDS' MOTION FOR SUMMARY JUDGMENT THIS CAUSE came before the Court upon the Defendant, BRADLEY J. EDWARDS' Motion for Summary Judgment in regard to the claims brought by the Plaintiff, JEFFREY EPSTEIN. The Court, after carefully considering the arguments
d raises even the slightest doubt that EFTA00602114 Epstein u. Rothstein, et al. Case No. 502009CA040800 AG Order Page 2 an issue might exist, Summary Judgment is precluded. Fatherly v. California Federal Bank, FSBO, 703 So.2d 1101 (Fla. 2nd DCA 1997). It hardly needs to be repeated that Summary Judgment c
BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800
e litigation privilege applies to malicious prosecution claims, as well as its finding that the litigation privilege was applicable specifically to Edwards's claims for malicious prosecution and abuse of process against Epstein, constituted issues of law. DelMonico, 116 So. 3d at 1211 (stating the dete
ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00589625 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle
RECEIVED, 2/25/2015 3:10 PM, Clerk, Fourth District Court of Appeal BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. / FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA04
e litigation privilege applies to malicious prosecution claims, as well as its finding that the litigation privilege was applicable specifically to Edwards's claims for malicious prosecution and abuse of process against Epstein, constituted issues of law. DelMonico, 116 So. 3d at 1211 (stating the dete
ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00714928 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle
t Lauderdale, FL 33301 ttorneys or e rey pstein Bradley J. Edwards, Esq. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHR
rclaim and Supporting Memorandum of Law, based on the law of the case doctrine. RELEVANT PROCEDURAL BACKGROUND In the Fourth Amended Counterclaim, Edwards raised two claims against Epstein: 1) abuse of process and 2) malicious prosecution. As to the malicious prosecution claim, Edwards alleged that th
ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00613594 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle
as quoted by the Wolfe Third District Court of Appeal opinion? MR. KING: There's nothing alleged. (T. 53-54). Accordingly, as explicitly stated in Edwards's own pleadings and discovery responses, and as conceded by Edwards's counsel at oral argument, the events giving rise to Edwards's purported claim
y served to the following on February 25, 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. 3409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Ste. 2 Mark Nurik Law Offices of Mark S. Nurik 1 E. Broward Blvd.
based on the undeniable holdings in Wolfe and the cases cited therein, Epstein's actions were absolutely protected by the litigation privilege and Summary Judgment was properly granted. Additionally, Appellant attempts to support his position by referencing the most recent Florida Supreme Court decision apply
Entities connected to both Bradley Edwards and Summary Judgment

Jeffrey Epstein
PERSONJack Goldberger
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Scarlett Johansson
PERSONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSONJaffe
PERSONTonja Haddad Coleman
PERSONGoldberger & Weiss
ORGANIZATION
George Mitchell
PERSON
Michael Jackson
PERSON
Supreme Court
ORGANIZATIONPalm Beach Lakes Blvd
LOCATIONAce Greenberg
PERSON
Adler
PERSON
JPMorgan Chase
ORGANIZATIONBurlington & Rockenbach
ORGANIZATION