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

ne Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶1148, 49. The litigation practices giving rise to pr

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

ane Doe v. Jefrey Epstein, 08-80893-C1V Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶¶ 48, 49. In addition, on July 24, 2009, while he wa

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA04080

, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. I East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fon Lauderdale, Florida 33301 Lilly Ann Sanchez, Esq. LS Law Fi

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

Epstein admits that some of the claims initially filed by him against Edwards are delineated in Paragraph 11 and its subparts, but submits that the Initial Complaint speaks for itself and that to the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph II of his Count

ndant(s). ORDER ON MOTION TO RECONFIRM EXISTING PRETRIAL DEADLINES g,v 25 73ne riem$4 -17.74497-.4t/ THIS CAUSE having come to be considered upon Bradley J. Edwards' MOTION TO RECONFIRM EXISTING PRETRIAL DEADLINES, and the Court having reviewed the file and being fully advised in the premises. it is hereby. ORD

rings are done -- is that I am going to require motions to be filed I A copy of the Court's Order is attached hereto as Exhibit 'A'. EFTA00793345 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 2 of 8 on a discovery issue-by-

rds adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 3 of 8 throughout Epstein's Initial Complaint. Any suggestion that L.M.'s deposition is needed "solely" as a result of the Court's December 5, 2017 ruling is therefore absurd. 4. Jane Doe is a

IRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR TEMPORARY ST

eme. Substantial discovery was taken by both parties. In 2012, Epstein voluntarily dismissed his complaint, and the sole remaining claim became Mr. Edwards' counterclaim for malicious prosecution. For the next five years, the parties litigated Mr. Edwards' claims in both the trial and appellate courts a

ial complaint, Epstein emphatically stated that "[t]his lawsuit is filed and will be vigorously pursued against all these defendants." See Epstein's Initial Complaint at `Summary'. (Emphasis added). In accordance with this representation to the Court, Epstein made no attempt to stay his newly-filed civil case pen