3
Shared Docs
3
Same-Page
6 / 3
Mentions
Appellate Case No. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants.1 REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI On Review of a Non-Final Order of the Circuit Court of
E.W. and Jane Doe have sought to intervene below on a limited and unrelated issue. As such, they are not parties in this certiorari proceeding, and Edwards has improperly captioned them as such on his Response. EFTA00808455 INTRODUCTION Disappointingly, Bradley Edwards ("Edwards") has used his Respo
despite having been joined at the hip with Epstein's claim against Rothstein since 2009— the risk of inconsistent verdicts is real. Instructive, is the Third District's opinion in Travelers Express Inc. v. Acosta, 397 So. 2d 733 (1981), in which the court considered whether a plaintiff's malicious prosecution claim
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
the course of litigation. This opinion reflects a direct conflict between the interpretation of the scope of the litigation privilege reflected in the Third District's Wolfe decision and the Fourth District's repeated and consistent recognition of the continued viability of the tort of malicious prosecution in 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
ious prosecution or abuse of process. The court certified conflict with Wolfe; the Florida Supreme Court ultimately approved Fischer and disapproved the Third District's decision in Wolfe. In its Opinion in this case, the Fourth District held that its decision in Fischer controlled as to the litigation privilege is
Entities connected to both Bradley Edwards and the Third District's

Jeffrey Epstein
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSONPalm Beach Lakes Boulevard
LOCATION
Michael Jackson
PERSONEmmy Taylor
PERSONPalm Beach County Courthouse
LOCATION
Tallahassee
LOCATIONPhilip M. Burlington
PERSON
the United States Supreme Court
ORGANIZATIONDaphne Wallace
PERSONWolfe
PERSONDade County
LOCATIONthe Fourth District's
LOCATION