Epstein Secrets

N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50-2009-CA-040800XXXXMBAG JUDGE HAFELE PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO: DEFE

t this Court's consideration of the probable cause issue raised in Epstein's motion for summary judgment is barred by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a point on appeal in Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015), and that

ON (App. *Ans Brf. at I, 7) (original emphasis). The footnote in question did not and could not raise a point on appeal. See Simkins Ind., Inc. v. Lexington Ins. Co., 714 So. 2d 1092, 1093 (Fla. 3d DCA 1998) (an argument in a footnote does not elevate the matter to a point on appeal."); R.J. Reynolds Tobacco Co.

N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50-2009-CA-040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO DEFEN

on for Summary Tonga Haddad. P.A. • 315 SE 7th Street, Fon Lauderdale, FL 33301. EFTA00808559 Judgment is batted by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a point on appeal in Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015), and that

PROSECUTION (App. 32, 41) (original emphasis). The footnote in question did not, and could not, raise a point on appeal. See Simkins Ind., Inc. v. Lexington Ins. Co., 714 So. 2d 1092, 1093 (Fla. 3d DCA 1998) ("an argument in a footnote does not elevate the matter to a point on appeal."); R.J. Reynolds Tobacco Co.

Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009 Page 17 of 18 Respectfully Submitted, Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id. The cases of U.S. v. Siegel, supra (11th Cir. 1998), and U.S. v. Edwards, supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of

ement with the United States Attorney's Office to not contest liability for claims brought exclusively 'See also Bray & Gillespie Management LLC v. Lexington Ins. Co., 2008 WL 4826115, 1 (M.D. Fla. 2008) — "Wile Court 'may take notice of proceedings in other courts, both within and without the federal judicial sy