Epstein Secrets

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

ews outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigat

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

time that Rothstein had been disbarred and the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigati

IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for

28 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court is

rds, Rothstein was deposed. At the morning session of deposition on December 12, 2011, Rothstein was asked the following about Bradley Edwards: Q: Brad Edwards, would he have reported illegal activity? A: I don't know. Q: Would he have reported trust account defalcations? 22 R. 816, citing letter dated Ju

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund sala

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

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,

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand Among the allegations in the Razorback Complaint regarding the Epstein cas

PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby

udgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me for Abuse of Process and Malicious Prosecution. 4. As more fully de

irm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salar

ALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 0408003OOO(MBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby

udgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me for Abuse of Process and Malicious Prosecution. 4. As more fully de

Razorback Complaint that the Epstein Cases were being deliberately misused for purposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is the fact that on July 24, 2009, Edwards filed a two hundred thirty-four (234) page, one fifty-six (156) count federal complaint against me on be

PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby

udgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me for Abuse of Process and Malicious Prosecution. 4. As more fully de

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co- conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salar