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

ed by Scott Rothstein, who was disbarred before he was 4 While the Ponzi Scheme was ongoing, RRA was prosecuting three civil cases against Epstein (the "Epstein Cases"). See pleadings in LM v. Jee•ey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein,

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

other dignitaries associated with him.5 [Cite Epstein 4 While the Ponzi Scheme was ongoing, RRA was prosecuting three civil cases against Epstein (the "Epstein Cases"). See pleadings in LM v. Jeffrey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein, 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein

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

gest Ponzi scheme in Florida's history. Also during that time RRA, through its partner, Edwards, was prosecuting three civil cases against Epstein (the "Epstein Cases"). After RRA imploded in early November 2009, Epstein learned, along with the rest of South Florida, about the Ponzi scheme, and that it was the Ep

Petrini, LLP 1320 Columbia Street, Suite 210 San Diego, California 92101-3436 He is expected to testify as to the lack of damages suffered by Mr. Edwards. 5. Mercedes Estrada Address unknown at this time As an employee of RRA mentioned in various documents, she is expected to testify regarding "Ep

ing the Ponzi scheme, the use of the "Epstein Cases" to defraud investors in the furtherance thereof while they were being prosecuted by RRA. 41. Bradley J. Edwards Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 He is expected to testify regarding hi

Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 He is expected to testify regarding the Ponzi scheme, use of the "Epstein Cases" in the furtherance thereof. 2. Ken Jenne do Broward County Sheriff's Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 33312-1308 He is expecte

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

gest Ponzi scheme in Florida's history. Also during that time RRA, through its partner, Edwards, was prosecuting three civil cases against Epstein (the "Epstein Cases"). After RRA imploded in early November 2009, Epstein learned, along with the rest of South Florida, about the Ponzi scheme, and that it was the Ep