Epstein Secrets

r reconsideration of this Court's non-final oral ruling denying summary judgment. For the reasons stated in this motion, Defendant/Counter Plaintiff Bradley J. Edwards' malicious prosecution claim fails as a matter of law on an essential element: the absence of probable cause for Epstein's underlying lawsuit. The C

l., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION FOR RECONSIDERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPP

tence of probable 2 EFTA00799340 United States of America v. Scott W. Rothstein, 09-6033 I-CR-COHN; Epstein's Answer and Affirmative Defenses to Edwards's Fourth Amended Counterclaim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Fu

se is encapsulated by the following paragraph from Edward's Opposition: Epstein knew that he had in fact molested each of the minors represented by Brad Edwards. He also knew that each litigation decision by Brad Edwards was grounded in proper litigation judgment about the need to pursue effective discovery

which was during the same period when, according to the Razorback Complaint, the Epstein cases were allegedly misused. See Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC

connection whatsoever to any specific claims of misconduct against the plaintiffs in the Epstein Cases. See letter dated 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the Epstein cases were

IAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BR

DS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"),

es of Civil Procedure, hereby files this Motion for Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution. In order to prevail on this count, Edwards must prove that there was an absence of probable c

he New York Times, the Wall Street Journal, the Florida Sun- Sentinal and other media outlets reported that Scott Rothstein, the partner of plaintiff Brad Edwards, had fled to Morocco to evade criminal prosecution for using their law firm, Rothstein, Rosenfeldt, Adler ("RRA"), to perpetrate a massive Ponzi sch

ims of RRA's fraudulent scheme described in the Razorback Complaint received $170,000,000 to settle their claims. [Cite] 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the fraudulent pleading

RIDA Complex Litigation, Fla. IL Civ. P. 1.201 Case No. 50 2009CA040800XVOCMB AG JEFFREY EPSTEIN, Plaintiff, V. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. I BANKRUPTCY TRUSTEE'S MOTION FOR PROTECTIVE ORDER Pursuant to Rule 1.410, Herbert Stettin,

nneth Jenne f. David Boden g. Deborah Villegas h. Andrew Barnett i. Patrick Rocberts j. Richard (Rick) Fandry k. Christina Kitterman I. Brad Edwards 22. All documents related to or referencing potential deponents in the Jane Doe, L.M. or E.W. cases. 6 EFTA00725173 23. All Q-Task "Projects"

, V. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendan

es: 1. On November 10, 2009, Rothstein Rosenfeld) Adler, P.A. ("RRA") was put into involuntary bankruptcy. That case is pending as In Re Estate of Rothstein Rosenfeld Adler, P,A., On November 20, 2009, Herbert Stettin was appointed Trustee of RRA. On November 30, 2009, an Order for Relief was entered by this Court. 2.

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

nces to supporting documentation. (R. 808-818). Those facts, along with the references as footnotes, are recounted below. Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009.' During that time, his firm was a front for the largest Ponzi scheme in Florida's history,2 and RRA,

d before you on October 11, 2013, and states: I. PROCEDURAL HISTORY In December 2009, Epstein filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"), based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners of

er 11, 2013, and states: I. PROCEDURAL HISTORY In December 2009, Epstein filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"), based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at

o do from an ethical standpoint. And then there were people who I would say would never do that. And then there are people in the middle. I believe Brad Edwards is probably in the middle. The standard for probable cause is whether the defendant "reasonably could have believed" that the person in the previou

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin

of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las O

s, LoCiero & Bralow, PL 101 N.E. 3rd Avenue Suite 1500 Fort Lauderdale, FL 33301-1181 Page 2 Pane 4 1 THE COURT: Last name is spelled? 2 MR. EDWARDS: Edwards. E-D-W-A-R-D-S. 3 THE COURT: Okay. 4 MR. OOLDBERGER: For the other side, Your Honor. 5 Jack Goldbaga along with Robert Critton on beha

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

Worn, Tallahassee hi, EFTA00616223 MAR-15-2011 TUE 05:39 PM FAX NO. P. 03/07 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. IN THE CIRCUIT COURT OF THE 15711 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. Ca

. Florida 33301 lallansit• EFTA00616225 MAR-15-2011 TUE 05:39 PM FAX NO. P. 05/07 SERVICE LIST Jeffrey Epstein v. Scott Rothstein, Bradley 3. Edwards and L.M. Caso No. 50 2009CA040800XXXXMB AG Mr. Robert D. Critton, Jr., Esq. Burman Critton Luttier & Coleman 303 Banyan Boulevard Suite 400 Wes

individually, and L.M., individually, Defendants. MOTION FOR FROTECTIVE ORDER FOR HERBERT STETTIN, TRUSTEE Herbert Stettin, Chapter 11 Trustee of Rothstein Rosenfeld Adler, P.A., ("RRA") hereby moves for a Protective Order as to a Subpoena issued upon him for records to be produced by March 16, 2011 and states: 1. F

s, LoCiero & Bralow, PL 101 N.E. 3rd Avenue Suite 1500 Fort Lauderdale, FL 33301-1181 Page 2 Pane 4 1 THE COURT: Last name is spelled? 2 MR. EDWARDS: Edwards. E-D-W-A-R-D-S. 3 THE COURT: Okay. 4 MR. OOLDBERGER: For the other side, Your Honor. 5 Jack Goldbaga along with Robert Critton on beha

of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las O

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

d before you on October 11, 2013, and states: I. PROCEDURAL HISTORY In December 2009, Epstein filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"), based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners of

er 11, 2013, and states: I. PROCEDURAL HISTORY In December 2009, Epstein filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"), based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin