Epstein Secrets

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA04080

RIDA CASE NO. 502009CA040800XxxxmBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Flor

02009CA040800XXXXMl3AG Jack Scarola, Esq. Searcy Denney Scarola et al. Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA Marc Munk, Esq. Bradlcy J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman Lilly Ann Sanchez, Esq. LS Law Finn Four Seasons Tower 10 EFTA00299008

11) (citing to American Nat. Title & Escrow of Florida. Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999)); See also. Montejo v. Marlin Memorial Medical Center, Ina, 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006). 8 EFTA00299006 Defendant specifically reserves the right here

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

passim McCullough v. Kubiak, 4DI3-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00589619 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA

EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. Case No. 50 2009 CA 040800XXXXMBAG Judge: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTI

thereof, Epstein states as follows: FACTS Epstein originally filed this action to recover damages from Defendant Scott Rothstein ("Rothstein") and Edwards, based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners, engaged in se

(July 17, 2013); American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999); see also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006). Finally, a copy of this Motion was provided to Edwards twenty-

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

passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00714922 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA

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

passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00613588 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA

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.

a. 3d DCA 2013); American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999). See also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006); Fridovich v. Fridovich, 598 So. 2d 65 (Ha. 1992) (stating that