Epstein Secrets

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and EL, individually, Defendant, RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT'S MOTION TO CONTINUE HEARING SCHEDULED FOR

tates as follows: Summary In 2009, Plaintiff/Counter-Defendant Jeffrey Epstein filed suit against attorney Bradley J. Edwards, alleging that Mr. Edwards had fabricated certain civil claims arising from Epstein's systematic sexual abuse of minor female children as part of a fraudulent Ponzi scheme th

stay this case is also barred by the doctrine of equitable estoppel, which has been a fundamental principle of American jurisprudence for centuries. Florida Dept. of Health & Rehab. Services v. S.A.P., 835 So. 2d 1091, 1096 (Fla. 2002). Equitable estoppel is "based on principals of fair play and essential ju

il and email transmittal to all those on the attached service list. Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, M. F , FL 33301 ax By: BRADLEY J. EDWARDS Florida Bar No.: SERVICE LIST Robert D. Critton, Jr. BURMAN CRITTON et al. LI est Palm Beach, FL 401 Jay Howell, Esq. Jay Howell & Assoc. Ja

attached service list. Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, M. F , FL 33301 ax By: BRA

of those cited by Epstein), "The courts of Florida have long recognized that the violation of a statute may be utilized as evidence of negligence." Florida Dept. of Corrections v. Abril, 969 So.2d 201, 205 (Fla. 2007). The only question, then, is how may the statutes be used as evidence of negligence. As th

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

ns of law actually decided on appeal must govern the case in the same court and the trial court, through all subsequent stages of the proceedings." Florida Dept. of Transp. v. Juliano, 801 So.2d 101, 105-06 (Fla. 2001) (citing Greene v. Massey, 384 So.2d 24, 28 (Fla. 1980) ("All points of law which have been

Critton, et al. 515 N. Flagler Drive, Ste. 400 West Palm Beach, FL 33401-4349 On behalf of Third Partylill. WILLIAM J. BERGER, 1 1 1 ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeldt Adler 1 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 14 15 1 On behalf of Third Party, The Post

Me. Shullman, good morning. Hr. Berger, good morning. And Mr. Borger, your client is E -- NR. BERGER: ., yes. THE COURT: Anybody else here? Nit. EDWARDS: Bred Edwards on behalf of as well, Judge. Thanks, EFTA00183597 1 2 3 4 5 6 7 8 9 10 11 12. 13 14 15 16 17 18 19 20 21 22

rcement of Crime Victim Rights Act, 18 U.S.C. § 3771 6 Defendants Jeffrey Epstein and Motion for Stay ' 7 Florida Sugar Cane League, Inc.'. Florida Dept. of Environmental Regulation, Case No. 91-2108 (Fla. 2d Jud. Cir.), 8 Order Releasing Public Records dated September 20, 1991 2 EFTA00183593