Epstein Secrets

roward Blvd., Ste. 700 Ft. Lauderdale, FL 33301 Bradley J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL

is case arises from Plainfiffitounter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit On Augustin 2011, Epstein served an Offer of Jud

ger & 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esquire 1 East Broward Blvd. Suite 700 Ft. Lauderdale FL 301 Bradley J. Edwards Esquire Staftefil Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue Suite 2 Ft. Lauderdale, FL 33301 Fred ' de I Financial Plaza S

, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Btoward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradle J. Edwards Es . brad Fan a e eissing 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es . tnancta aza Suite 2612 Fort Lauderda

N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counte•-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.

oceeding are absolutely privileged, so long as the actions have some relation to the underlying proceeding. Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 SO. 2d 606, 608 (Fla. 1994). This position was reaffirmed in Echevarria. In Wolfe, the Third District Court of Appeal, quoting in large p

Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel, hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442: 1. This Proposal is being made pursuant to §768.79, Fla. Stat. and Fla. R

s Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter- Plaintiff Bradley Edwards ("Edwards"). In support of thereof, Epstein states as follows: INTRODUCTION; On August 25, 2011, Epstein served an Offer of Judgment on Edwards in the amoun

ndant, JEFFREY EPSTEIN, against Defendant/Counter- Plaintiff, BRADLEY EDWARDS, individually, and the claims brought by Defendant/Counter- Plaintiff, BRADLEY EDWARDS, Individually, sinst Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, with prejudice, each party to bear its own costs and attorney's fees. The part

d grants summary judgment in favor of Epstein. EXIIILT "II" EFTA00805524 The Court thoroughly reviewed Levin, Midcllebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe v. Foreman, 3

, FLORIDA CIVIL DIVISION -AG CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. I ORDER GRANTING COUNTER-DEFENDANT, JEFFREY EPSTEIN'S. MOTION FOR SUMMARY JUDGM I NT THIS CAUSE ca

heard argument of counsel and being otherwise advised in the premises, it is hereupon ORDERED AND ADJUDGED: 1. Mr. EPSTEIN filed suit against Mr. EDWARDS and Mr. EDWARDS thereafter filed a Counterclaim against Mr. EPSTEIN. Mr. EPSTEIN later dismissed his Complaint without prejudice. The Counterclaim

9CA040800XXXXMB of action for both abuse of process and malicious prosecution. 3. The court has reviewed Levin, Middlebrooks. Moves & Mitchell. v. U.S. Fire Ins. Co., 639 So.2d 606, 608 (Fla. 1994), Bchevarria, McCalla. Ravmer, Barrett & Frappier v. Cole, 950 Sold 380 (Fla. 2007) and Wolfe v. Foreman 38 Fla

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

Supreme Court in Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell,.. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), the decision by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the

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

eme Court in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), the decision by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the