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r reconsideration of this Court's non-final oral ruling denying summary judgment. For the reasons stated in this motion, Defendant/Counter Plaintiff Bradley J. Edwards' malicious prosecution claim fails as a matter of law on an essential element: the absence of probable cause for Epstein's underlying lawsuit. The C
l., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION FOR RECONSIDERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPP
tence of probable 2 EFTA00799340 United States of America v. Scott W. Rothstein, 09-6033 I-CR-COHN; Epstein's Answer and Affirmative Defenses to Edwards's Fourth Amended Counterclaim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Fu
se is encapsulated by the following paragraph from Edward's Opposition: Epstein knew that he had in fact molested each of the minors represented by Brad Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation judgment about the need to pursue effective discovery
which was during the same period when, according to the Razorback Complaint, the Epstein cases were allegedly misused. See Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC
S. 317, 323 (1986). "Just because conflicting evidence exists does not mean probable cause is a jury question." C.A. Hansen Corp. v. Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, M., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 604
IAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BR
DS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"),
es of Civil Procedure, hereby files this Motion for Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution. In order to prevail on this count, Edwards must prove that there was an absence of probable c
he New York Times, the Wall Street Journal, the Florida Sun- Sentinal and other media outlets reported that Scott Rothstein, the partner of plaintiff Brad Edwards, had fled to Morocco to evade criminal prosecution for using their law firm, Rothstein, Rosenfeldt, Adler ("RRA"), to perpetrate a massive Ponzi sch
S. 317, 323 (1986). "Just because conflicting evidence exists does not mean probable cause is a jury question." C.A. Hansen Corp. v. Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, P.A., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 6
ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos Lehrman 42
r granting Epstein's motion for summary judgment, this Court recounted the following background facts: EFTA00808205 [Epstein] filed suit against [Edwards]. Edwards then filed a counter- claim against Epstein. Epstein subsequently dismissed his Complaint without prejudice. The counter-claim proceeded,
. 317, 323 (1986). "Just because conflicting evidence exists does not mean probable cause is a jury question." C.A. Hansen Corp. v. Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, P.A., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 6
Entities connected to both Bradley Edwards and Blomqvist

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONTonja Haddad Coleman
PERSONAtterbury
ORGANIZATION
Lauderdale
LOCATIONPalm Beach Lakes Blvd
LOCATIONFlorida Bar
ORGANIZATIONFred Haddad
PERSONSearcy Denney Scarola
PERSON
South Florida
LOCATION
Adler
PERSON