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Service List: Jack Scarola, Esq. Searcy, Denney, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach. FL 33409 Email: Bradley J. Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, et al 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 E-Mail: Marc S. Nurik, Esq. Marc S. Nu
nt, VS. SCOTT ROTHSTEIN, individually, BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs.
h Lakes Blvd. West Palm Beach. FL 33409 Email: Bradley J. Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, et al 425 Nor
Esq. Haddad & Navarro, PLLC I Financial Plaza, Suite 2612 Fort Lauderdale FL 33394 E-Mails: Tonja Haddad Coleman, Esq. Tonja Haddad, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale. FL 33301 E-Mails: EFTA00601681
good faith basis for my filing these claims against Mr. Edwards because there was this case filed down in Broward County that never even mentions Bradley Edwards' name. And he can't come and stand before Your Honor and say, as he just did through Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00788196
EFTA00788113 3 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: We have various motions on the Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious prosecution. I have read as much as the materials
19 20 21 22 23 24 25 things until the Ponzi scheme gets uncovered and he seizes upon the Ponzi scheme as a means by which to try to extort Bradley Edwards into abandoning the legitimate interest of his clients or compromising those interests for less than those interests were worth. THE COURT: Let's
S. Australian Avenue, Suite 33401 West Palm Beach, FL 33401 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Av
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
33301 • .. lwards, E . Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Fred Haddad, Es 315 S.E. 7th Street, Suite 301 Ft. Lauderdale, FL 33301 Tonja Haddad Coleman, Esq. Law Offices of Tonja Haddad, P.A. 315 S.E. 7th Street, Suite 301 Ft. Lauderdale,
ACH COUNTY, FLORIDA Case Pa. 502009CAO40B00/COM 1 4 THE COURT: Announce your appearances for the Court, MR. SCAROLA: Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Chester Brewer on behalf Plaintiff, of Jeffrey Epstein. SCOTT ROTHSTEIN, individbally, BRADLEY SWA
MR. SCAROLA: Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Ch
.A., ESQUIRE 21 THE COURT: You had mentioned that to 10 22 me. 11 For Jeffrey EpeteLn: 12 TONJA HADDAD, P.A. 19 MR. SCAROLA: Yes, sir. 315 S.E. 7th Street, Suite 301 14 And, obviously, our response to the 13 Fort Lauderdale, FL 33301 15 motion for sumnary judgment, as wall, which By TONJA HADDAD
ry important distinction when Your Honor comes to ruling upon whether these lines of inquiry are relevant at all. Does it make any difference what Bradley Edwards' motive was, what his subjective thought processes were in filing a motion in the context of a pending case to require the posting of a bond if re
otion to overrule objections and compel Defendant/ Counter-Plaintiff Bradley Edwards' answer to questions. Judge, this motion is directed at Mr. Edwards' deposition testimony and the two depositions he provided in this case, the first of which was March 23rd, 2010, the second of which was May 15th,
S. Australian Avenue, Suite 33401 West Palm Beach, FL 33401 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Av
Entities connected to both Bradley Edwards and S.E. 7th Street

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONDarren Indyke
PERSONPalm Beach Lakes Boulevard
LOCATIONTonja Haddad Coleman
PERSONGoldberger & Weiss
ORGANIZATION
Les Wexner
PERSON
Palm Beach
LOCATIONAtterbury
ORGANIZATIONPalm Beach Lakes Blvd
LOCATIONFred Haddad
PERSON