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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
tes upon which each and every purported abuse of process occurred, Edwards again replied: "the date of service of each of the above as reflected on the Certificate of Service of each." Accordingly, Edwards has not pointed to, and indeed cannot point to, one act either outside of or extrinsic to the litigation, undeniably
UIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXX MB AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). / PROCEEDINGS HELD BEFORE JUDGE DONALD HAFELE PLAINTIFF'S MOTION TO SET CASE FOR TRIAL H
21 22 23 24 25 the 23rd -- MR. SCAROLA: I'll have somebody else cover for me, sir. I don't want this matter delayed being set for trial. Mr. Edwards is co-counsel with me in this matter, and he will be here if I'm not available. I have offered those alternatives to the other side, and I am just
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 today? MR. SCAROLA: I would only note, your Honor, as is reflected on the Certificate of Service, in my communications with Miss Haddad I mentioned four law firms representing Mr. Epstein. There are in fact five law firms representing Mr. Epst
EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, Counter-Defendant, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. Case No. 50 2009 CA 040800XXXXMBAG Judge: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTI
thereof, Epstein states as follows: FACTS Epstein originally filed this action to recover damages from Defendant Scott Rothstein ("Rothstein") and Edwards, based upon Epstein's well-founded belief at the time of filing his Complaint that these two individuals, and other unknown partners, engaged in se
nd every purported abuse of process occurred, Edwards again replied: "the - 5 - EFTA00612154 date of service of each of the above as reflected on the Certificate of Service of each." See Answers to Interrogatories filed June 10, 2011. Edwards has not pointed to, and indeed cannot point to, one act either outside of or
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
tes upon which each and every purported abuse of process occurred, Edwards again replied: "the date of service of each of the above as reflected on the Certificate of Service of each." Accordingly, Edwards has not pointed to, and indeed cannot point to, one act either outside of or extrinsic to the litigation, undeniably
da 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 19, 2013 DELIVERY BY FEDERAL EXPRESS Brad Edwards, Esq., Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 Re: Jane Doe #1 and Jane Doe #21. Uni
July 19, 2013 DELIVERY BY FEDERAL EXPRESS Brad Edwards, Esq., Fanner Jaffe Weissing Edwards Fistos Lehr
Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to
ensive disposition of the litigation, or serve as a means of controlling the district court's docket. See American Manufacturers Mutual Ins. Co. v. Edward,. Stone Jr. & Assoc., 743 F.2d 1519 (11th Cir. 1984). For example, a stay may be considered in a case where there is another pending lawsuit or admi
Stay is defective and should be stricken. The Motion to Stay also raises due process concerns because it was not served on all parties according to the Certificate of Service accompanying the Motion. The Defendant has not yet filed an appearance in the case, and his response to the Complaint is not yet due. The Motion to
Entities connected to both Bradley Edwards and the Certificate of Service

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
United States
LOCATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Adam D. Horowitz
PERSON
Bill Clinton
PERSON
Sarah Kellen
PERSON
Palm Beach County
LOCATIONTonja Haddad Coleman
PERSONStuart S. Mermelstein
PERSON
Barry Diller
PERSON
Jeffrey Marc Herman
PERSONFlorida Bar
ORGANIZATION