Epstein Secrets

r reconsideration of this Court's non-final oral ruling denying summary judgment. For the reasons stated in this motion, Defendant/Counter Plaintiff Bradley J. Edwards' malicious prosecution claim fails as a matter of law on an essential element: the absence of probable cause for Epstein's underlying lawsuit. The C

l., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION FOR RECONSIDERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPP

tence of probable 2 EFTA00799340 United States of America v. Scott W. Rothstein, 09-6033 I-CR-COHN; Epstein's Answer and Affirmative Defenses to Edwards's Fourth Amended Counterclaim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Fu

se is encapsulated by the following paragraph from Edward's Opposition: Epstein knew that he had in fact molested each of the minors represented by Brad Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation judgment about the need to pursue effective discovery

which was during the same period when, according to the Razorback Complaint, the Epstein cases were allegedly misused. See Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution act

amination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individually; 0 Rocones-Exaninatien by Mr. Lick 138 BRADLEY EDWARDS, Individually, 9 Further Redirect Examination by Mr. Scarola 160 Defendants/Counter-Plaintiff. 10 Certificate of Oath 170 / 11 Certificate

5 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE , This deposition is being hold 2255 Glad

would moan -- for example, 1 when you aay -- it wasn't during the time of the 2 Mr. Scarola's firm represented a client against 2 Rothstein -- Brad Edward➢ wasn't working for the ) Mr. Epstein, right? ) Rothstein firm, I don't believe, when this happened. 4 A Correct. 4 Q When he settled? 5 Q

So I served on the 12 Fourth District and served with a panel of judges 13 and heard quite a number of cafes and wrote several 14 decisions for the Fourth District. Q The jury may not be familiar with the 14 procedure, but when the appellate court reviews 17 decision➢ that are rendered and jury trial re➢ul

good faith basis for my filing these claims against Mr. Edwards because there was this case filed down in Broward County that never even mentions Bradley Edwards' name. And he can't come and stand before Your Honor and say, as he just did through Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00788196

EFTA00788113 3 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: We have various motions on the Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious prosecution. I have read as much as the materials

19 20 21 22 23 24 25 things until the Ponzi scheme gets uncovered and he seizes upon the Ponzi scheme as a means by which to try to extort Bradley Edwards into abandoning the legitimate interest of his clients or compromising those interests for less than those interests were worth. THE COURT: Let's

cted the summary judgment on probable cause and bona fide termination. We filed an appeal. That case was briefed. And prior to the oral argument, the Fourth District rejected the Wolfe case. Now, what happened in the briefing in our case is our initial brief addressed solely litigation privilege, because that

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231347 2 1 ON BEHAL

ately ad s these fa rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of Assistant State-Attorney Barbara Burns-was present on behalf-of-the Sta

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232467 2 1 ON BEHAL

equately ad•` s fa ;•rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos Lehrman 42

r granting Epstein's motion for summary judgment, this Court recounted the following background facts: EFTA00808205 [Epstein] filed suit against [Edwards]. Edwards then filed a counter- claim against Epstein. Epstein subsequently dismissed his Complaint without prejudice. The counter-claim proceeded,

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution ac

3301 54)467-1223 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esq. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHR

f/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter- sued Epstein for, inter al

y to make an informed decision of acceptance or rejection. One aspect of Swartsel was disagreed with by the Supreme Court in Nichols. In Swartsel, the Fourth District held parties were required to specify all terms of a settlement (882 So.2d at 453). Then in Nichols, the Supreme Court held parties could summarize

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

-3456 Telecopier (954) 527-8663 By: Bradley J. Edwards Florida Bar No. 542075 bcdwardsarra-law.com Wi

ld a stay not be 769 So.2d 389, 391 n.4 (Fla. 3d DCA 1999). Defendants fail to adequately ad completely ignores the likelihood likelihood that the Fourth District would reverse for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan paragraph 3 of his motion. Here, Defe

Epstein v. Edwards Page 1 of 1 From: John Beranek > To: wcbiew ; wcbcg Subject: Epstein v. Edwards Date: Mon. Jun 16, 2014 4:06 pm Chet -- I have reviewed what

rt has ruled on the issue and the district court really has no choice. I would be happy to discuss it further and I think my job would be to remind the Fourth District that their decision got reversed in Echevarria. Let me know if you want to talk about it on the phone or what you want to do next. Sincerely, Joh