Epstein Secrets

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

a claim for punitive damages on the ground that Epstein's claims against him had no basis and were retaliatory. On April 13, 2011, Epstein filed an Amended Complaint against Edwards, which . Edwards moved to dismiss. On July 13, 2011, this Court entered an Order denying Edwards' first motion for leave to assert

Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009 Page 17 of 18 Respectfully Submitted, Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id. The cases of U.S. v. Siegel, supra (11th Cir. 1998), and U.S. v. Edwards, supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of

are also raised in the case of v. Jeffrey Epstein, Case No. 08-CV-80811-MARRA/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff 's Amended Complaint, Plaintiff .'s Response, and Defendant's reply to .'s response (which has yet to be filed). In this action, Plaintiffs Complaint attempts to alle

the penalty or punishment for the alleged crime. U.S. Const. Art. 1, §9, cl. 3, §10, cl. 1. U.S. v. Seigel, 153 F.3d 1256 (11th Cir. 1998); U.S. v. Edwards, 162 F.3d 87 (3d Cir. EFTA00222820 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 9 of 29 Jane Doe II v. Epstein, e

raised in the case of C.M.A. v. Jeffrey Epstein Case No. 08-CV-80811-MARRA/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and Defendant's reply to C.M.A.'s response (which has yet to be filed). In this action, Plaintiffs Complaint attempts