Epstein Secrets

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

So. 2d 356 (Fla. 2d DCA 2007) 17, 22 Pardo v. State, 596 So. 2d 665 (Fla. 1996) 12 Procacci v. Zacco, 402 So. 2d 425 (Fla. 4th DCA 1981) 21 R.H. Ciccone Properties, Ina v. JP Morgan Chase Bank, N.A., 141 So. 3d 590 (Fla. 4th DCA 2014) 15 Rivernider v. Meyer, Case Number 4D14-819 10 SCI Funeral Services of

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

So. 2d 356 (Fla. 2d DCA 2007) 17, 22 Pardo v. State, 596 So. 2d 665 (Fla. 1996) 12 Procacci v. Zacco, 402 So. 2d 425 (Fla. 4th DCA 1981) 21 R.H. Ciccone Properties, Ina v. JP Morgan Chase Bank, N.A., 141 So. 3d 590 (Fla. 4th DCA 2014) 15 Rivernider v. Meyer, Case Number 4D14-819 10 SCI Funeral Services of

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.

ements made during the course of a judicial proceeding extends not only to the parties, but to judges, witnesses and counsel as well.") In fact, in R.H. Ciccone Properties, Inc. v. JP Morgan Chase Bank, N.A., 141 So. 3d 590 (Fla. 4th DCA 2014), this Court correctly recognized that "'[t]he purpose of the litigation pri