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N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50-2009-CA-040800XXXXMBAG JUDGE HAFELE PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO: DEFE
t this Court's consideration of the probable cause issue raised in Epstein's motion for summary judgment is barred by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a point on appeal in Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015), and that
ble cause, but referenced only the issue of bona fide termination. Because the issue of bona fide termination was the sole tipsy coachman argument, the Fourth District's decision not to disturb this Court's evaluation of that issue does not bar Epstein, by operation of the law of the case doctrine, from presenting h
ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION
and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in
proceedings, something which this Court recognized at the May 23, 2018, hearing is properly before it in light of the new trial schedule created by the Fourth District's rulings. (5/23/18 Tr. 13:9-23.)4 Moreover, none of the general references for which Edwards would have Epstein sanctioned violated any privileges o
CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF EDWARDS' MOTION FOR RECONSIDERATION Bradley Edw
OTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF EDWARDS' MOTION FOR RECONSIDERATION Bradley Edwards hereby files this notice of his reliance upon the additional authority attached, and would show that th
reliance upon the additional authority attached, and would show that the attached opinion of the Fourth District Court of Appeal further evidences the Fourth District's adherence to the universally accepted recognition that claims for malicious prosecution are an exception to the litigation privilege's absolute bar
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
ion [was] based continue to be the facts of the case." Juliano, 801 So.2d at 106. Therefore, the law of the case doctrine binds this Court to follow the Fourth District's holding (and therefore this Court's prior determination) on this issue. The Fourth District Court of 4 EFTA00613504 Appeal has already affirmed
Entities connected to both Bradley Edwards and the Fourth District's

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSONPalm Beach Lakes Boulevard
LOCATIONTonja Haddad Coleman
PERSON
George Mitchell
PERSONBroward
LOCATIONPhilip M. Burlington
PERSONWolfe
PERSON
Donald Hafele
PERSONAppellant
ORGANIZATIONValdes
PERSONGAB Robins
ORGANIZATION