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30 Marc S. Nurik, Esq. LAW OFFICES OF MARC S. NURIK One E. Broward Boulevard, Ste. 700 Ft. Lauderdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, Ste. 2 Ft. Lauderdale. FL 33301-3268 Attormeys for Bradley J. Edwards EFTA00808548
on and the procurement of minors to engage in prostitution and further agreed to be registered as a sex offender (App.13, p.133). Bradley Edwards ("Edwards") is a civil attorney who represented multiple victims of Epstein's serial abuse of children. Edwards filed three civil actions against Epstein in
derdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, St
ett v. Continental Chemicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A. 1 204 So.3d 476 (Fla. 4th DCA 2016) Gawker Media, LLC v. Bollea 20, 21, 22 170 So.3d 125 (Fla. 2d DCA 2015) Grossman v. Fla. Power & Light Co., 14 570 So.2d 992 (Fla. 2d DCA 1990) Haft v. Adam
CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM TRIAL DOCKET IN ORDER TO COMPLY WITH
ein's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate Set Forth in Rule 1.440, and in support states as follows: 1. As Edwards has argued for months, Epstein has no intention of ever trying this malicious prosecution case. At the eve of every trial date, Epstein files a host
ther institute or continue the underlying proceeding against Edwards. But Epstein will not admit his wrongdoing and is once again attempting to drag Brad Edwards' name and reputation through the mud, and this time wants to drag many others in as well. 16. Epstein and his counsel, however, benefit (so far) fr
at all of the claims or counterclaims in those cases involved the same parties that were involved in the underlying complaint. 10. For example, in Gawker Media, LLC v. Bollea 170 So. 3d 125 (Fla. 2d DCA 2015), the case primarily relied upon by Epstein, the plaintiff, Bollea, sued multiple defendants, one of
ellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REPLY TO RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review of a Non-Final Order of the Circuit
Confronted with Rule 1.440, a compulsory rule of Florida Civil Procedure, and unequivocal legal precedent interpreting the same clearly against him, Edwards levels false and misleading accusations against Epstein and injects impertinent allegations into his argument in an obvious attempt to divert the C
also Tucker, 175 So. 3d at 306 13 EFTA00808484 (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Gawker Media, LLC, 170 So. 3d at 129-30 (granting mandamus to enforce Rule 1.440 and holding that an appeal after final judgment would be insufficient to remedy
gument in his consolidated appeals from Judge Donald Hafele's March 8, 2018 rulings which resulted in two non-final orders, (1) granting Respondent Bradley J. Edwards' Motion for Separate Trials and (2) denying Petitioner's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate in Rule 1.440.
"exempts only cross-claims from the determination of when an action is at issue."). The issues raised in these consolidated appeals were created by Edwards' eleventh-hour misuse of Rule 1.440 in a maneuvering effort to achieve severance or bifurcation of his counterclaim from the original claim filed b
ance"); Genuine Pans Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006)(issuing a writ of mandamus to enforce strict toning of Rule 1.440(c)); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015)("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440, includ
plaintiff/counter-defendant below, challenges the circuit court's Order entered March 8, 2018' by the Honorable Donald Hafele, granting Respondent Bradley J. Edwards' Motion for Separate Trials.'' By separate motion, Petitioner moves to consolidate this petition with his pending Emergency Petition for Writ of Man
admittedly running a $1.2 billion Ponzi scheme by convincing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All bac
Schoof, 190 So. 3d 169, 170 (Ha. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015) ("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440, inclu
DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review of a Non-Final Order of the Circuit Court of the Fifteen
ocess d. (4) Fraud e. (5) Conspiracy to Commit Fraud (App. 1). On December 21, 2009, just 17 days after Epstein instituted the civil proceeding, Edwards filed a Counterclaim for abuse of process against Epstein. (App. 2). Thereafter, Edwards amended his Counterclaim several times, ultimately allegi
. Wells Fargo Bank, N.A., 204 So. 3d 476, 479 (Fla. 4th DCA 2016) (citing Genuine Parts Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006) and Gawker Media, LLC v. Bollea, 170 So. 3d 125, 130 (Ha. 2d DCA 2015)). I In compliance with this Court's Administrative Order No. 2014-1, the Petitioner has cont
DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY MOTION FOR REVIEW OF ORDER DENYING STAY Pursuant to Florida Rule of Appellate Procedure 9.310(0,
is case on August 9, 2010. (App. 5). 2 EFTA00793768 (App. 1). On December 21, 2009, just 17 days after Epstein instituted the civil proceeding, Edwards filed a Counterclaim for abuse of process against Epstein. (App. 2). Thereafter, Edwards amended his Counterclaim several times, ultimately allegi
nscript. Epstein will supplement his Appendix with the Court's Order once entered. 7 See Bennett, 492 So. 2d at 727; Teelucksingh, 21 So. 3d at 37; Gawker Media, LLC, 170 So. 3d at 131; Genuine Pans Co., 917 So. 2d at 421. 7 EFTA00793773 The purpose of mandamus is "to enforce the respondent's unqualified
s' attorney BYLINE: MICHELE DARGAN Daily News Staff Writer BODY: Billionaire sex offender Jeffrey Epstein filed his 2009 lawsuit against attorney Brad Edwards in an effort to get Edwards to drop sex abuse lawsuits filed against Epstein, attorney Jack Scarola said Friday. "The sole motivation for these cla
AN Daily News Staff Writer BODY: Billionaire sex offender Jeffrey Epstein filed his 2009 lawsuit against attorney Brad Edwards in an effort to get Edwards to drop sex abuse lawsuits filed against Epstein, attorney Jack Scarola said Friday. "The sole motivation for these claims against Mr. Edwards is a
zebel Jezebel August 4, 2010 Wednesday 1:00 PM EST LENGTH: 1373 words HEADLINE: The Sex-Trafficking Model Scout [Predators] BODY: Aug. 4, 2010 (Gawker Media delivered by Newstex) Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a promine
Entities connected to both Bradley Edwards and Gawker Media

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSON
George W. Bush
PERSON
Donald Trump
PERSONPalm Beach Lakes Boulevard
LOCATIONGoldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Lauderdale
LOCATION
Scott J. Link
PERSON
Naomi Campbell
PERSONPalm Beach County Courthouse
LOCATIONDonald W. Hafele
PERSON
Chris Tucker
PERSON
Searcy
PERSON
Melbourne
LOCATIONNichole J. Segal
PERSONBurlington & Rockenbach
ORGANIZATION