EFTA00613391Set 9
2016-02-0150p13,597w
DERSHOWITZ,
Defendant/Counterclaim Plaintiff.
DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN M. DERSHOWITZ'S
MOTION FOR LEAVE TO AMEND COUNTERCLAIM AND FOR LEAVE TO
ASSERT CLAIM FOR PUNITIVE DAMAGES AGAINST
PLAINTIFFS/COUNTERCLAIM DEFENDANTS EDWARDS AND CASSELL ... Defendant and Counterclaim Plaintiff, Alan M. Dershowitz ("Dershowitz"), pursuant to
Florida Rules of Civil Procedure 1.170(a), 1.170(e), 1.190(a) and 1.190(f) and Florida Statute
§ 768.72, hereby respectfully ... entry of an order granting Dershowitz leave to
file his proposed Second Amended Counterclaim, attached as Exhibit A, which includes (a) two
additional counts for defamation against Plaintiffs / Counterclaim Defendants
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf
EFTA01112610Set 9
2011-11-2116p4,697w
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
MOTION TO DISMISS SECOND AMENDED COUNTERCLAIM
AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his
undersigned counsel ... hereby moves to dismiss the Second Amended Counterclaim of the
Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS ("Edwards"), and in support thereof
states as follows:
I. SUMMARY OF ARGUMENT
Edwards' Second Amended Counterclaim ... Counterclaim") should be dismissed because
Edwards has added nothing substantively to distinguish this Counterclaim from the Amended
Counterclaim that this Court has already dismissed and, just as was the case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112610.pdf
EFTA00793881Set 9
34p23,564w
spending an inordinate amount of court
29 case. He didn't oven move his counterclaim 29 resources, and now taking the position that
24 to set for trial, he moved ... case 16 team, dating back to 2011, now constitutes
)7 globally, main claim and counterclaim -- 17 reason for this case to be stricken?
10 which is appropriate, because ... Does that not sound inequitable? Does
19 counterclaim arises from the main claim -- 19 that not sound inappropriate? Does that not
20 he entered into a joint stipulation 20 sound
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793881.pdf
EFTA00801275Set 9
90p17,710w
need a default, he moved the
13 case. He didn't even move his counterclaim
14 to set for trial, he moved the case.
15 And then further, to evidence ... Edwards' intent to try this case
17 globally, main claim and counterclaim
18 which is appropriate, because the
19 counterclaim arises from the main claim --
20 he entered into ... answer to that question
11 is clearly yes.
12 Severance of a permissive
13 counterclaim -- and there is no doubt about
14 the fact that this is a permissive
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801275.pdf
EFTA00808455Set 9
2010-09-0816p3,535w
adhered to throughout the course of this
litigation to justify a malicious prosecution counterclaim against Epstein for which
Edwards has no factual or legal support. In fact, Edwards' counterclaim ... deter this Court from finding that
the trial court's severance of Edwards' counterclaim was a clear departure from the
essential requirements of law and will cause irreparable injury ... consolidated mandamus
proceeding that has been separately briefed); and (2) that Edwards' malicious
prosecution counterclaim against Epstein is inextricably and undisputedly factually
intertwined with, and cannot be severed from, Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808455.pdf
EFTA00722309Set 9
2010-05-2120p4,025w
JEEPERS, INC.,
Respondent § Case No. 1425006537
and
FINANCIAL TRUST COMPANY, INC. and §
JEEPERS, INC.,
Counterclaimants and Third-Party Claimants §
v.
Arbitrator: Hon. Anthony J. Carpinello
D.B. ZWIRN SPECIAL OPPORTUNITIES §
FUND ... compliance the Scheduling Order No. 1.
DEFINITIONS AND INSTRUCTION
1. The term "Counterclaim" means the Response, Counterclaim, and Third-Party
Claim, filed in this arbitration ... Daniel
Zwim in this arbitration on June 25, 2010.
4. The term "Counterclaimants" or "Third-Party Claimants" means (a) Financial
Trust Company, Inc.; and (b) Jeepers, Inc. The term includes
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722309.pdf
EFTA00793693Set 9
2018-03-0824p4,964w
suit,
Edwards countersued based on Epstein's original complaint. After several
iterations of his counterclaim, Edwards ultimately alleged a count for malicious
prosecution. In his malicious prosecution counterclaim, Edwards alleged ... later dismissed Edwards
from the suit without prejudice, his claim against Rothstein and Edwards'
counterclaim against Epstein are alive and well and have traveled together since
the inception of this ... lawsuit.
Edwards' counterclaim is based on the alleged "anxiety" and "emotional
distress" he suffered as a result of Epstein's filing and continuation of this lawsuit.
At the March
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793693.pdf
EFTA00808471Set 9
2012-03-2718p4,063w
capitalize on that issue with a last-minute
request for bifurcation of his counterclaim. (App. 15.)' Indeed, after the parties
and the trial judge himself had overlooked the Rule ... hour when Edwards improperly sought to exploit this Rule 1.440
problem to bifurcate his counterclaim against Epstein from Epstein's claim against
Rothstein (originally against both Rothstein and Edwards ... Edwards attempts to give this Court the false impression that
Edwards' counterclaim against Epstein and Epstein's claim against Edwards' former
partner, convicted felon Scott Rothstein, are separate and unrelated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808471.pdf
EFTA01099134Set 9
2015-03-0226p11,196w
CASSELL,
Plaintiff(s),
vs.
ALAN M. DERSHOWITZ,
Defendant(s).
COUNTER-DEFENDANTS' MOTION TO DISMISS COUNTERCLAIM
Plaintiffs/Counterclaim-defendants Bradley J. Edwards and Paul G. Cassell, by and
through their undersigned counsel, hereby ... move to dismiss the Counterclaim of
defendant/counterclaim-plaintiff Alan M. Dershowitz.
Edwards and Cassell have filed a complaint against Dershowitz arising out of
Dershowitz's international defamatory assault on Edwards ... Cassell. In response, Dershowitz
has filed a counterclaim alleging two counts of defamation by Edwards and Cassell: Count I,
concerning statements in a pleading filed in federal court; and Count
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099134.pdf
EFTA01076581Set 9
2009-12-2130p7,583w
MOTION FOR JUDGMENT ON THE PLEADINGS
OR ALTERNATIVE MOTION FOR SUMMARY JUDGMENT ON
EDWARDS' COUNTERCLAIM FOR ABUSE OF PROCESS
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant ... moves for
summary judgment pursuant to Fla. R. Civ. P. 1.510(b), on the Counterclaim for abuse
of process filed by Defendant/Counter-Plaintiff, Bradley J. Edwards ("Edwards"), and
states:
Background ... December 21, 2009, Edwards answered the Complaint filed by Epstein
and asserted a Counterclaim (attached as Exhibit A).
2. Epstein filed a Motion for More Definite Statement and Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076581.pdf
EFTA01111371Set 9
2011-04-1514p4,048w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111371.pdf
EFTA01111399Set 9
2011-04-1514p4,051w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111399.pdf
EFTA01111344Set 9
2011-04-1513p3,706w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
/
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111344.pdf
EFTA01112592Set 9
2011-04-1514p4,092w
CLERK & COMPTROLLER
Defendants. CIRCUIT CIVIL DIVISION
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
PlaintifUCounter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112592.pdf
EFTA01111385Set 9
2011-04-1514p4,058w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111385.pdf
EFTA01111357Set 9
2011-04-1514p3,942w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
/
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111357.pdf
EFTA01108461Set 9
2011-04-1514p4,011w
individually,
BRADLEY J. EDWARDS, individually,
Defendants.
/
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS
AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), 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 ... counsel, filed a Complaint naming Edwards as
a defendant. Edwards filed an Answer and Counterclaim for abuse of process. The Court denied
Epstein's motion to dismiss Edwards' Counterclaim. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA01108461.pdf
EFTA01099525Set 9
2014-01-28140p21,399w
ANSWER
Filing Date: 21-DEC-2009
Filing Party: EDWARDS,BRADLEYJ
Disposition Amount:
Docket Text: & COUNTERCLAIM ...
10 MSTR- MOTIONTO STRIKE
Filing Date: 128-DEC-2009
Filing Party:
Disposition Amount:
Docket Text ... EFTA01099532
- Not an Official Document 1/28/14 12:17 PM
Disposition Amount:
Docket Text: EDWARDS' COUNTERCLAIM
24 NOH - NOTICE OF HEARING
Filing Date: 26-FEB-2010
Filing Party: EPSTEIN, JEFFREY
Disposition ... EFTA01099534
- Not an Official Document 1/28/14 12:17 PM
!Docket Text: COUNTERCLAIM
iIIO
36 RADF - REPLY TO AFFIRMATIVE
DEFENSES
Filing Date: I16-MAR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099525.pdf
EFTA01076899Set 9
2010-05-039p2,443w
Judgment on the Pleadings and/or Motion for Summary Judgment on Edwards'
1 144PE
WITHAM Counterclaim for Abuse of Process.
4 1eASSACIOSETTS
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WASIMSTOU ... COUNTERDEFENDA
FOR SUMMARY JUDGMENT
JUDGMENT ON THE PLEADINGS AND/OR MOTION PROCESS
ON EDWARDS' COUNTERCLAIM FOR ABUSE OF
nse and Supporting
Defendant/Counterplaintiff, Bradley J. Edwards, files this Respo
ant, Jeffrey Epstein ... Motion for
Legal Authorities in Opposition to PlaintifftCounterdefend
ent on Edwards' Counterclaim for
Judgment on the Pleadings and/or Motion for Summary Judgm
Abuse of Process and states:
ment pursuant
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076899.pdf
EFTA00611281Set 9
2009-12-2120p4,607w
EDWARDS,
individually, and L.M., individually,
Defendants.
EPSTEIN'S MOTION TO DISMISS EDWARDS'S COUNTERCLAIM
Plaintiff, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.140(b),
moves to dismiss ... Counterclaim for abuse of process filed by Defendant, Bradley J.
Edwards ("Edwards"), and states:
1. On December 21, 2009, Edwards answered the Complaint filed by Epstein
and asserted a Counterclaim ... Epstein filed a Motion for More Definite Statement and Motion to Dismiss
Edwards's Counterclaim as it was unclear what cause of action Edwards was
attempting to assert
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611281.pdf