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.

ation of the case, although many nominal offers have been accepted by the courts as made in good faith. See Fox v. McCaw Cellular Communications of Florida, Inc., 745 So. 2d 330 (FM. 4th DCA 1998); Neptune Beach v. Smith, 740 So. 2d 25, 27 (Ha. 1st DCA 1999). In the case at hand, Edwards filed a Counterclaim

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

ation of the case, although many nominal offers have been accepted by the courts as made in good faith. See Fox v. McCaw Cellular Communications of Florida, Inc., 745 So. 2d 330 (Fla. 4th DCA 1998); Neptune Beach v. Smith, 740 So. 2d 25, 27 (Fla. 1st DCA 1999). In the case at hand, Edwards filed a Countercla

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

ABLE OF CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

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

acts," warranting sanctions. § 57.105 FLA. STAT. (2012); Wolfe v. Foreman, 38 FLA. L. WEEKLY D1540 (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 12

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

F CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

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

F CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

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.

just as occurred in the Wolfe case, mandating Summary Judgment. Wolfe v. Foreman, 128 So. 3d 67 (Fla. 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 12

IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA BRADLEY J. EDWARDS and PAUL G. CASSELL, CASE NO.: 15-000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSIDERATION OF THIS

issued by Plaintiff that was improperly served upon Epstein. As grounds therefor, Epstein states: INTRODUCTION The Plaintiff, Bradley J. Edwards ("Edwards"), and Epstein are involved in a separate and distinct lawsuit from the case at hand in the Fifteenth Judicial Circuit, in and for Palm Beach Count

that a non-resident of the State; or even the County, cannot be served with a subpoena while attending court proceedings. See also Lee v. Stevens of Florida, Inc., 578 So. 2d 867, 868 (Fla. 2d DCA 1991) (extending that protection to those attending alternative dispute resolution). This Court, however, denied

OR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR FEES AND COSTS AND INCORPORATED MEMORANDUM

is 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 amount

ation of the case, although many nominal offers have been accepted by the courts as made in good faith. See Fox v. McCaw Cellular Communications of Florida, Inc., 745 So. 2d 330 (Fla. 4th DCA 1998); Neptune Beach v. Smith, 740 So. 2d 25, 27 (Fla. 1st DCA 1999). In the case at hand, Edwards filed a Countercla