Epstein Secrets

Florida, this day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT O

day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT OF THE FIFTEENTH JUD

is day of , 2009SAGOO et -, IREml VA r e `0 • David French' . Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., D EDWARDS, ESQ., Brad Edwards and Associates. , JAY HOWELL, ESQ., Jay Howell & Associates, PA, iterbuly Goldberger & Weiss. P.A. EFTA00722689 g e sz LEOPO

tprfl=HTMLEttifm=NotSet&mt... 4/10/2009 EFTA00722723 Page 3 of 3 800 So.2d 706 800 So.2d 706,26 Fla. L. Weekly D283I (Cite as: 800 So.2d 706) (Fla.1999), the supreme court again discussed 800 So.2d 706,26 Fla. L. Weekly D2831 Langston and, without expressly overruling it, stated that the principle

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

tein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") legally and factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwar

ird, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS'." See Exhibit B. However, because Edwards has put his financial status at issue by his assertion of damages, his Motion must be denied. When a party

s inordinate." Topp Telecom, Inc. v. Atkins, 763 So. 2d 1197, 1199 (Fla. 4th DCA 2000). See also Allstate Ins. Co. v. Boecher, 733 So. 2d 993, 994 (Fla.1999) (noting the lack of "affidavits, depositions or other sworn testimony in the record to support Allstate's claims."). Here, Edwards fails to do so,

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

ll be upheld if there is any basis which would support the judgment in the record." Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla.1999). "This rule applies in cases of summary judgments as well." Landis v. Allstate Ins. Co., 546 So. 2d 1051, 1053 (Fla. 1989); see also Rivernider, su

s O ) .1 •s--• tAtin Beach, it Our' c C•T David French Vr- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL, ESQ., Jay Howell & Associates, PA.. and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger EFTA0061441

, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL,

MLEttifm=NotSet&mt... 4/10/2009 EFTA00614453 Page 3 of 3 800 So.2d 706 Page 2 800 So.2d 706, 26 Fla... Weekly D2831 (Cite as: 800 So.2d 706) (Fla.1999), the supreme court again discussed 800 So.2d 706, 26 Fla.'. Weekly D2831 Langston and, without expressly overruling it, stated that the principle