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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
ss 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 Edwards is barred
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
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 Edwards is entitl
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
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 - FOWLER WHITE
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
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 process apart from t
Entities connected to both Bradley Edwards and U-Haul Co.

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Harvey Weinstein
PERSONJoseph L. Ackerman
PERSONPalm Beach Lakes Blvd
LOCATIONJUDICIAL CIRCUIT
ORGANIZATIONDavid F. Crow
PERSONComplex Litigation
ORGANIZATION
FOWLER
ORGANIZATIONFla. Stat.
ORGANIZATIONValdes
PERSONESPIRITO SANTO PLAZA
ORGANIZATION
McMurray
LOCATIONDella-Donna
PERSON