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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
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. See Information Charging Scott W. Rothstein in United States of America v. Scott W. Rothstein, 09-60331-CR-COHN. Scott Rothstein, Edwards's partne
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
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in the Ro
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,
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in the Ro
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
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. 11. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in th
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
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. 11. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press, in the Razorback Complaint, and in th
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
d to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. 3 E FTA_R1_00008497 EFTA01733724 11. Prior to filing the initial Complaint in the Action, consistent with the allegations made by the press,
Entities connected to both Bradley Edwards and the RRA Enterprise

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
Adler
PERSON
David Copperfield
PERSON