Epstein Secrets

E. The Present Motion to Compel I0 ARGUMENT 11 I. EDWARDS MAY NOT RELY ON THE VACATED DISTRICT COURT ORDER FROM THE JANE DOE ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance to

a deposition in one of the now-settled suits by implying that "he did not recognize" reporter Rush. Moving Br. at 17; see also Moving Affidavit of Bradley James Edwards, sworn to Sept. 14, 2010 ("Edwards Aft"), ¶ 22. Besides being farfetched and factually unsupported, Edwards' apparent desire to attack Epstein's cr

pstein sex abuse litigation, as even a quick Google search reveals. See. e.g., Heiress Quizzed in Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how

lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assi

is not an affirmative post-issuance misuse of process"); SW Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. Dist. Ct. App. 2010); Yoder v. Adriatico, 459 So.2d 449, 450 (Fla. Dist. Ct. App. 1984) ("the tort of abuse of process is concerned with the improper use of process after it issues"). Thus,

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

RIDA CASE NO. 502009CA040800XxxxmBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Flor

02009CA040800XXXXMl3AG Jack Scarola, Esq. Searcy Denney Scarola et al. Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA Marc Munk, Esq. Bradlcy J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman Lilly Ann Sanchez, Esq. LS Law Finn Four Seasons Tower 10 EFTA00299008

ce of the charges or allegations contained in the first suit." See Doss v. Bank of America, N.A., 857 So. 2d 991, 994 (Fla. 5th DCA 2003). See also Yoder v. Adriatico. 459 So. 2d 449, 451 (Fla. 5th DCA 1984) (stating that the tort of malicious prosecution requires. as an element, the prior termination of that clai

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

nce of the charges or allegations contained in the first suit." See Doss v. Bank of America, N.A., 857 So. 2d 991, 994 (Fla. 5th DCA 2003). See also Yoder v. Adriatico, 459 So. 2d 449. 451 (Fla. 5th DCA 1984) (stating that the tort of malicious prosecution requires, as an element, the prior termination of that cla

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

e to allege any improper willful acts by the appellees during the course of the prior action requires dismissal of the abuse of process claim..."); Yoder v. Adriatico, 459 So. 2d 449, 450 (Fla. 51h DCA 1984)("the tort of abuse of process is concerned with the improper use of process after it issues")(emphasis add

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

e to allege any improper willful acts by the appellees during the course of the prior action requires dismissal of the abuse of process claim..."); Yoder v. Adriatico, 459 So. 2d 449, 450 (Fla. 5'h DCA 1984)("the tort of abuse of process is concerned with the improper use of process after it issues")(emphasis add