Epstein Secrets

RITTON: Good morning. Plaintiff. 6 MR. SCAROLA: Good morning, Judge. SCOTT ROTHSTEIN, individually, 7 THE WITNESS: Were here on Epstein versus BRADLEY J. EDWAFtDS, individually, and L.M. individually, Defendants. / 8 9 10 Rothstein, et al. So, I've read the materials you guys submitted on both sides and

ins, RPR, FPR 22 judgment than it is a claim for a judgment on Notary Public, State of Florida 23 the pleadings. Prose Court Reporting 24 Mr. Edwards argues through his counsel Job No . 1783 25 that, in essence, Mr. Epstein's a bad person. Page 2 Page 4 APPEARANCES: 1. So no matter what hap

criminal, tinder the 9 court properly found that Russell showed — and 10 Civil Theft Statute 772.11. One, we think it's 10 again this is in the McMurray case — the 11 not applicable. Two is we don't think notice 11 non-existence of a genuine issue of material 12 is required. It's part of the -- t

ling. 4 my client in the counterclaim are really 4 And they go down and they cite relying on 5 Paragraphs 9, 10, and II. And the key is the 5 McMurray versus U-Haul which is the Fourth 6 action was filed for the sole purpose to 6 District case, which holds that the mere filing 7 intimidate Edw

IVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECON

um Of Law In Opposition To Damages Pled In Bradley Edwards' Second Amended Counterclaim, and states as follows: In his Second Amended Counterclaim, Edwards seeks the following damages from Epstein for alleged abuse of process: injury to Edwards' reputation, "interference in his professional relationshi

ng of that lawsuit. Fifth, abuse of process is based on process used for an immediate purpose other than that for which it was designed. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208 and n. I (Fla. 4th DCA 1983). Edwards, however, does not allege that any specific process was used by Epstein for an

tedly baseless lawsuit. Given the fact that the mere filing or service of a spurious claim is not itself actionable as abuse of process, see, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980), it necessarily follows that Edwa

IVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRA

m Of Law In Opposition To Damages Pled In Bradley Edwards' Second Amended Counterclaim, and states as follows: In his Second Amended Counterclaim, Edwards seeks the following damages from Epstein for alleged abuse of process: injury to reputation, "interference in his professional relationships, the l

ch requires abuse of the judicial system subsequent to the filing of a complaint — not purportedly unfounded allegations in a complaint. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980). Finally, to the extent that Edw

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 RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' M

FREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the following response in opposition to Defendant/Counter- Plaintiff EDWARDS' ("Edwards") Motion for Leave to Assert a Claim for Punitive Damages ("motion")" and states: SUMMARY OF ARGUMENT Edwards' latest kitchen-sink moti

r purpose after an action was filed and process served. See,. e.g., Della-Donna v. Nova University, Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987); McMurray v. U-Haul Co, Inc., 425 So. 2d 1208, 1209-10 (Fla. 4th DCA 1983). Accordingly, the filing of an action itself does not constitute abuse of process.

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

, 443 So. 2d 1025, 1026 (Fla. 2d DCA 1986)(counterclaim allegedly causing undue expenditure of time and money did not constitute abuse of process); McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4'h DCA 1983)(same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980)("[N]o abuse of the - 4 -

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 FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAR

-Plaintiff Bradley Edwards' Counterclaim, and states as follows : I. SUMMARY OF ARGUMENT Summary judgment should be entered in favor of Epstein on Edwards' single-count Counterclaim for abuse of process because it is legally insufficient. Edwards' Counterclaim does not state an actionable claim for ab

, 443 So. 2d 1025, 1026 (Fla. 2d DCA 1986)(counterclaim allegedly causing undue expenditure of time and money did not constitute abuse of process); McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4'h DCA 1983)(same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980)("[N]o abuse of the proces