Epstein Secrets

IBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of IN THE CIRCUI

ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis

and punish Epstein for his crimes against them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See Edwards Affidavit, "N" at ¶7. Included in thi

ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorn

notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exhibit "N" at 116. 74. Edwards gave notice that he intended to take David Copperfield's deposition. Edwards p

IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for

28 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court is

rds, Rothstein was deposed. At the morning session of deposition on December 12, 2011, Rothstein was asked the following about Bradley Edwards: Q: Brad Edwards, would he have reported illegal activity? A: I don't know. Q: Would he have reported trust account defalcations? 22 R. 816, citing letter dated Ju

18th day of September, 2015, a copy of the foregoing was emailed to those on the list below. s/ Paul Morris SERVICE LIST: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. Philip M. Burlington Burlington & Rockenbach, P.A. Imo Tonja Haddad Coleman -18- EFTA00612500 W. Chester Brewer, Jr. W. Chest

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

aced. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy was electronically served to the following on February , 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.

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.

ced. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy was electronically 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 Av

FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA BRADLEY J. EDWARDS, CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 Appellant, v. JEFFREY EPSTEIN, Appellee. I MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS

amount of these fees and costs has not yet been determined. This award was based on the fact that Epstein filed a good faith Offer of Judgment which Edwards rejected. A copy of the February 3, 2015 order is attached. A copy of the Motion for Attorney's Fees and Costs with other relevant pleadings is als

the trial court to determine the amount of the fees and costs. I HEREBY CERTIFY that electronically to the following this William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.