EFTA00607599Set 9
13p2,966w
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
FOURTH AMENDED COUNTERCLAIM
Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges:
COUNT I-ABUSE ... State and Federal criminal
laws.
EFTA00607599
Edwards adv. Epstein
Case No.: 502009CA040800/00C<MBAG
Fourth Amended Counterclaim
Page 2 of 13
5. EPSTEIN was sued civilly by a large number ... Federal
Crime Victims' Rights Act (CVRA).
EFTA00607600
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Fourth Amended Counterclaim
Page. 3 of 13
8. While prosecuting the legitimate claims on behalf
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607599.pdf
EFTA01187868Set 9
13p2,924w
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
FOURTH AMENDED COUNTERCLAIM
Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges:
COUNT I-ABUSE ... State and Federal criminal
laws.
EFTA01187868
Edwards adv. Epstein
Case No.: 502009CA040800/00C<MBAG
Fourth Amended Counterclaim
Page 2 of 13
5. EPSTEIN was sued civilly by a large number ... Federal
Crime Victims' Rights Act (CVRA).
EFTA01187869
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Fourth Amended Counterclaim
Page. 3 of 13
8. While prosecuting the legitimate claims on behalf
https://www.justice.gov/epstein/files/DataSet%209/EFTA01187868.pdf
EFTA01112467Set 9
2010-03-2327p8,263w
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION
FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM AND
SUPPORTING MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his
undersigned ... Civil Procedure,
files this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley
Edwards's Fourth Amended Counterclaim, and in support thereof states the following:
I. PROCEDURAL HISTORY
In December 2009, Epstein ... ARGUMENT
Summary Judgment should be entered in favor of Epstein on Edwards's Fourth
Amended Counterclaim (hereinafter "Counterclaim"). First, regarding his Abuse of
Process claim, Edwards does not allege
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112467.pdf
EFTA01105418Set 9
13p2,930w
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
M., individually,
Defendant,
FOURTH AMENDED COUNTERCLAIM
Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges:
COUNT I-ABUSE ... State and Federal criminal
laws.
EFTA01105418
Edwards adv. Epstein
Case No.: 502009CA040800/00C<MBAG
Fourth Amended Counterclaim
Page 2 of 13
5. EPSTEIN was sued civilly by a large number ... Federal
Crime Victims' Rights Act (CVRA).
EFTA01105419
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Fourth Amended Counterclaim
Page. 3 of 13
8. While prosecuting the legitimate claims on behalf
https://www.justice.gov/epstein/files/DataSet%209/EFTA01105418.pdf
EFTA00621880Set 9
13p2,958w
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
M., individually,
Defendant,
FOURTH AMENDED COUNTERCLAIM
Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges:
COUNT I-ABUSE ... State and Federal criminal
laws.
EFTA00621880
Edwards adv. Epstein
Case No.: 502009CA040800/00C<MBAG
Fourth Amended Counterclaim
Page 2 of 13
5. EPSTEIN was sued civilly by a large number ... Federal
Crime Victims' Rights Act (CVRA).
EFTA00621881
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Fourth Amended Counterclaim
Page. 3 of 13
8. While prosecuting the legitimate claims on behalf
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621880.pdf
EFTA01112494Set 9
2010-03-2327p8,305w
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION
FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM AND
SUPPORTING MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his
undersigned ... Civil Procedure,
files this Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley
Edwards's Fourth Amended Counterclaim, and in support thereof states the following:
I. PROCEDURAL HISTORY
In December 2009, Epstein ... ARGUMENT
Summary Judgment should be entered in favor of Epstein on Edwards's Fourth
Amended Counterclaim (hereinafter "Counterclaim"). First, regarding his Abuse of
Process claim, Edwards does not allege
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112494.pdf
EFTA00808609Set 9
2018-01-1711p2,448w
Second
Amended Counterclaim (November 29, 2011), Third Amended Counterclaim (May 21, 2012) and
Fourth Amended Counterclaim (January 9, 2013).
13. Epstein therefore had, at a minimum, six (6) years ... Second Amended Counterclaim (November 29, 2011), Third Amended Counterclaim (May
21, 2012) and Fourth Amended Counterclaim (January 9, 2013).
15. Any discovery related to this issue could, and should, have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808609.pdf
EFTA00585394Set 9
2010-03-2326p10,566w
against
Epstein the sole issue in his litigation against Epstein, see Edwards's Fourth Amended
Counterclaim, 9¶ 24-33, he cannot now hide behind an alleged privilege when asked ... outside the scope of discovery. For example, in Paragraph 24 of Edwards's
Fourth Amended Counterclaim, he specifically alleges that while prosecuting the cases against
Epstein ... never had
any reasonable basis to believe otherwise." See Edwards's Fourth Amended Counterclaim, ¶ 24.
Edwards must prove this allegation, and every other allegation, to prevail.
OTHER OBJECTIONS
The following
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585394.pdf
EFTA00801507Set 9
2010-03-2318p5,756w
JEFFREY EPSTEIN'S RENEWED MOTION
FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY
EDWARDS'S FOURTH AMENDED COUNTERCLAIM AND SUPPORTING
MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned ... Summary Judgment on the sole remaining count of Defendant/Counter-
Plaintiff Bradley Edwards's Fourth Amended Counterclaim; Malicious Prosecution, and in
support thereof states the following:
I. PROCEDURAL HISTORY
In December ... lawsuit against Edwards and Scott
Rothstein for Abuse of Process. See Edwards's Fourth Amended Counterclaim. Epstein has
continually maintained that Edwards did not, and cannot, establish a cause
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801507.pdf
EFTA00799402Set 9
2010-03-2326p10,584w
outside the scope of discovery. For example, in Paragraph 24 of Edwards's
Fourth Amended Counterclaim, he specifically alleges that while prosecuting the cases against
Epstein ... never had
any reasonable basis to believe otherwise." See Edwards's Fourth Amended Counterclaim, ¶ 24.
Edwards must prove this allegation, and every other allegation, to prevail.
OTHER OBJECTIONS
The following ... regarding same. See Deposition of Bradley Edwards 2010 and 2013. However, in
his Fourth Amended Counterclaim Edwards claims to have suffered the following special damages:
"a. injury to his reputation
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799402.pdf
EFTA00619811Set 9
2017-06-3017p5,616w
Defendants/Counter-Plaintiff.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR
SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY
EDWARDS' FOURTH AMENDED COUNTERCLAIM AND SUPPORTING
MEMORANDUM OF LAW
Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned ... Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff
Bradley Edwards' ("Edwards") Fourth Amended Counterclaim, Malicious Prosecution.
INTRODUCTION
In order to prevail on his claim of Malicious Prosecution, Edwards must ... Rothstein, 09-60331-CR-COHN; Epstein's
Answer and Affirmative Defenses to Edwards' Fourth Amended Counterclaim; Deposition
Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler
https://www.justice.gov/epstein/files/DataSet%209/EFTA00619811.pdf
EFTA01112386Set 9
2013-09-114p791w
FILE AN AMENDMENT TO HIS ANSWER AND AFFIRMATIVE DEFENSES
TO DEFENDANT/COUNTER-PLAINTIFF'S FOURTH AMENDED
COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Rule ... filing of the accompanying
Amended Answer and Affirmative Defenses to Edwards's Fourth Amended
Counterclaim to conform with the evidence. In support of this Motion, Epstein states:
Rule ... affirmative defenses when he filed his Answer and Affirmative
Defenses to Edwards's Fourth Amended Counterclaim. Here, justice requires the
amendment of Epstein's Affirmative Defenses because, if properly established
https://www.justice.gov/epstein/files/DataSet%209/EFTA01112386.pdf
EFTA00800481Set 9
2010-03-2326p10,542w
against
Epstein the sole issue in his litigation against Epstein, see Edwards's Fourth Amended
Counterclaim, 9¶ 24-33, he cannot now hide behind an alleged privilege when asked ... outside the scope of discovery. For example, in Paragraph 24 of Edwards's
Fourth Amended Counterclaim, he specifically alleges that while prosecuting the cases against
Epstein ... never had
any reasonable basis to believe otherwise." See Edwards's Fourth Amended Counterclaim, ¶ 24.
Edwards must prove this allegation, and every other allegation, to prevail.
OTHER OBJECTIONS
The following
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800481.pdf
EFTA00583952Set 9
2010-03-2330p9,571w
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583952.pdf
EFTA00799339Set 9
2010-03-2326p8,044w
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 ... Summary Judgment on the sole remaining count of Defendant/Counter-
Plaintiff Bradley Edwards's Fourth Amended Counterclaim, Malicious Prosecution. In the
alternative, pursuant to [Rule 1.540? — on the grounds of Mistake ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799339.pdf
EFTA01107639Set 9
2013-01-0914p2,871w
thereof, Epstein states:
INTRODUCTION
On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim
against Epstein, asserting therein that he suffered the following damages: "a) injury ... baseless claims." Edwards likewise claims an entitlement to
punitive damages. See Edwards's Fourth Amended Counterclaim.
On April 23, 2013 Epstein, in defending this action, served upon Edwards an
Amended ... items directly related
1
EFTA01107639
to Edwards's allegations of damages in his Fourth Amended Counterclaim. A true and
correct copy of the Amended Notice and "Schedule A" are attached
https://www.justice.gov/epstein/files/DataSet%209/EFTA01107639.pdf
EFTA01084920Set 9
2013-02-1410p2,387w
JEFFREY EPSTEIN'S AMENDED ANSWER
AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Rule ... this Amended Answer and Affirmative Defenses to DefendanUCounter-Plaintiff
Bradley Edwards's ("Edwards") Fourth Amended Counterclaim ("Counterclaim"), and states:
1. Epstein admits that the Counterclaim alleges an amount within ... Affirmative Defense, Epstein asserts that the causes of action described
in Edwards's Fourth Amended Counterclaim were commenced based upon the good faith
8
EFTA01084927
advice of an attorney
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084920.pdf