Epstein Secrets

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

15 EFTA00808533 C. Epstein Waived the Right to Rely on Rule 1.440 Epstein has waived reliance on Rule 1.440. As discussed above, Epstein filed the Second Amended Complaint on August 22, 2011. Rothstein never answered the complaint. Pursuant to Rule 1.500(a), Florida Rules of Civil Procedure, it was incumbent upon Epst

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

ded Complaint, which was filed on August 21, 2011. 4. Edwards, however, is not a party to that case as Epstein voluntarily dismissed Edwards from the Second Amended Complaint on August 16, 2012.' That point alone nullifies Epstein's entire argument that Edwards' Motion to Set Case for Trial was not ripe. Rule 1.440(b), o

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

Edwards filed a "Supplement" to his Motion for Separate Trials (App. 15). In his Supplement, Edwards advised for the first time that no default on the Second Amended Complaint had been entered in Epstein's case against Rothstein. In other words, at the time Edwards filed his motion to set case for trial, 7 EFTA00793699

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

m., in a "Supplement" to his Motion for Separate Trials filed just the day before (App. 14), Edwards asserted for the first time that no default on the Second Amended Complaint had been entered in Epstein's case against Rothstein. In other words, at the time Edwards filed his motion to set case for trial, the case was not

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

recognized the case was not at issue at the time the motion to 5 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit court grants Epstein's motion for default. Thereafter,

iff/Counter-Defendant, vs. 4 the court. It has caused me to have to SCOTT ROTHSTEIN, individually; 7 engage in an inordinate amount of time to BRADLEY EDWARDS, individually, 8 the exclusion of other natters that needed Defendants/Counter-Plaintiffs. 4 my attention. 10 While the Court understands the

thank Hr. Cassell for being here today. Your Honor, this is Mr. Epstein's motion to remove this case from the trial docket. It was prompted by Mr. Edwards' motion to separate the trials, which was motion -- for the obvious reason, when he • filed his motion to sot the case in the above-styled cause

longer applied. Mr. Edwards pointed out to this Court and to Mr. Epstein -- he is absolutely correct -- that Mr. Epstein's operative complaint is the Second Amended Complaint to which there is no default. What rule 2.440 tolls this Court to do is to look at the time that Mr. Edwards moved -- it's maybe a notice to set

A JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW

n"), by and through his undersigned counsel, hereby moves to dismiss the Amended Counterclaim of the Defendant/Counter-Plaintiff, BRADLEY EDWARDS ("Edwards"), and in support thereof states as follows : I. SUMMARY OF ARGUMENT Edwards' Amended Counterclaim should be dismissed because it fails to state a

ended Complaint which contained a single count against Edwards for abuse of process, and a single count against Rothstein. Edwards moved to dismiss the Second Amended Complaint. At the September 28, 2011 hearing on Edwards' motion to dismiss the Second Amended Complaint, the Court explained that abuse of process required -