Epstein Secrets

3432 7 8 ROTHSTEIN, ROSENFELDT & ADLER 9 BY: BRADLEY J. EDWARDS, ESQ., 401 East Las Olas Boulevard 10 Suite 1650 Fo

hat are involved 6 here, so we can get started. 7 Mr. Berger, go right ahead. 8 MR. BERGER: Good morning, Your Honor. 9 William J. Berger and Brad Edwards for the 10 moving parties, and that's who's the 11 Plaintiff in one case today, and then there's 12 III., who's a Plaintiff in another case th

rd to the 13 non-prosecution agreement and what happened. 14 If the Court will also recall, the NPA is 15 under, basically, a freeze order. Mr. Edwards, 16 on behalf of two of his Jane Does, tried to get 17 that order so it would become public. Judge 18 Marra said, no, and they keep trying and

om the essential requirement of law in granting this discovery," and it refers to a case called Smith vs. TIB Bank of the Keys, 687 So.2d. 895, a Third District case, 1997, and that quotation then from that case by the Fifth in the Ballast case says "by alleging fraud as well as breach EFTA00776412 48 1

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408007OOOCMBAG

-Plaintiff Bradley Edwards's ("Edwards") Complaint, Abuse of Process and Malicious Prosecution, and entered Final Judgment in accordance therewith. Edwards timely appealed this Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and o

A 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Ntwil Es Es . 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradle J. Edwards Es . anner a e eissing wards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad Es . Fre Ha a , PA 1 Financi

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding

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

EFTA00231327 Page 2 of I I Wdstlaw. 76912d 389 769 2d 389 Fla. L. Weekly D2439 (Cite as: 769 ..241 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appel lee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties

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

00232447 Page 2 of Wdstlaw. 769 So.2d 389 769 So.2d 389.24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant. v. Jorge M. PEREZ, Appel lee. No. 99-2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties

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

law presented in the case at hand, and conducts a detailed analysis of the seminal Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

AL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Monday, January 27, 2014 TIME: 3:00 p.m. - 4:23 p.m. PLACE: Palm Bea

had no knowledge whatsoever 4 that a separate and independent action had been 5 brought by Mr. Epstein against the Rothstein 6 entities and Mr. Edwards. So to that extent, I 7 just to want let you know, as you probably already 8 did already know, that I handled those cases I 9 believe to their

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The 17 standard is: Did the action have some relation

ward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. [email protected] Fanner Jaffe Weissing Ed

-Plaintiff Bradley Edwards's ("Edwards") Complaint, Abuse of Process and Malicious Prosecution, and entered Final Judgment in accordance therewith. Edwards timely appealed this Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and o

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding

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

al to this Court and is set for Oral Argument on April 28, 2015. 10 EFTA00714933 Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

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

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The :7 standard is: Did the action have some relation

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

80827 Page 2 of I I Westlaw 769 So.2d 389 769 So.2d 389, 24 Ha. L. Weekly D2439 (Cite as: 769 So.2d 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appellee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties