EFTA00583952Set 9
2010-03-2330p9,571w
COUNTY
JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG
Plaintiff/Counter-Defendant, JUDGE HAFELE
v.
BRADLEY J. EDWARDS, et al.,
Defendant/Counter-Plaintiffs.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR
SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY
EDWAFtDS ... files this
Motion for 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 ... absence of
probable cause at the time that Epstein filed suit against Edwards. The threshold of facts
sufficient to establish probable cause that will defeat Edwards' claim for malicious prosecution
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583952.pdf
EFTA00602439Set 9
2016-01-1361p36,119w
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and PAUL G.
CASSELL,
Plaintiffs,
vs.
ALAN M. DERSHOWITZ,
Defendant.
VIDEOTAPE CONTINUED DEPOSITION OF
ALAN ... York, New York
BY: DARREN K. INDYKE, ESQ. (Via phone) 6 Bradley Edwards and Paul Cassell versus Alan
6 7 Dershowitz.
7 On behalf of 8 My name is Marcy ... their appearances for the record.
BY: SIGRID STONE MCCAWLEY, ESQ.
10 smecawley@bsfilp.com 12 MR. EDWARDS: Sure. On behalf of the
11 13 plaintiff today Brad Edwards. Jack Scarola
12 ALSO
https://www.justice.gov/epstein/files/DataSet%209/EFTA00602439.pdf
EFTA01120533Set 9
2010-06-3029p8,593w
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
M, individually,
Defendant(s).
=tOUNTER-PLAINTIFF, EDWARDS' SECOND RENEWED MOTION FOR LEAVE ... ASSERT CLAIM FOR PUNITIVE DAMAGES
Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court for entry of an
Order granting him leave to assert a claim for punitive damages against ... punitive damage claim. Specifically, the
evidence establishes that EPSTEIN's Complaint against EDWARDS;
1. was filed in the total absence of evidence to support any allegation of wrongdoing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120533.pdf
EFTA00806757Set 9
2018-11-2656p13,446w
BEACH COUNTY
Case No. 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
DEFENDANT/COUNTER-PLAINTIFF'S SECOND AMENDED PROPOSED JURY
INSTRUCTIONS AND VERDICT FORM ... Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, by and through undersigned
counsel, hereby files his Second Amended Proposed Jury Instructions and Verdict Forms for trial
in the above-styled matter. These Second Amended ... Instruction When Firest Item of
Documentary, Photographic or Physical
Evidnece is Admitted
EFTA00806757
EDWARDS ADV. EPSTEIN
Case No.: 502009CA040800XXXXMBAG
Defendant/Counter-Plaintiff's Second Amended Proposed Jury Instructions and Verdict Form
Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806757.pdf
EFTA00584532Set 9
2017-07-1222p6,124w
COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMB
JEFFREY EPSTEIN,
Plaintiff,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY EDWARDS, individually,
Defendants.
PLAINTIFF'S SUPPLEMENTAL MOTION TO COMPEL DISCOVERY'
Plaintiff, Jeffrey Epstein ("Epstein"), pursuant ... moves for an
order compelling Defendant, Bradley Edwards ("Edwards"), to provide complete and responsive
answers to interrogatories dated July 12, 2017, September 5, 2017, and October ... production dated September 5, 2017, and
October 13, 2017, and in support states:
INTRODUCTION
Edwards is not a victim. Edwards is a lawyer who loves the spotlight
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584532.pdf
EFTA00081180Set 9
2010-03-1740p13,196w
807m09 roio-< uoc 16q0,3 e 0
EXHIBIT C
Epstein vs. Edwards
Undisputed Statement of Facts
EFTA00081181
Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger p hri N 7NRocieatgfe ... 040800XXXKMBAG
JEFFREY EPSTEIN,
Plaintiff,
VS.
SCOTT ROTHSTEIN, individually, and
BRADLEY I EDWARDS, individually,
Defendants,
STATEMENT OF UNDISPUTED FACTS
Defendant Bradley J. Edwards, Esq., offers the following specific facts ... Fifth Amendment right to remain
silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference
against Epstein that, had Epstein answered, the answer would have
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081180.pdf
EFTA00613391Set 9
2016-02-0150p13,597w
CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and
PAUL G. CASSELL,
Plaintiffs/Counterclaim Defendants,
vs.
ALAN M. DERSHOWITZ,
Defendant/Counterclaim Plaintiff.
DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN ... 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 ... which includes (a) two
additional counts for defamation against Plaintiffs / Counterclaim Defendants Bradley J.
Edwards ("Edwards") and Paul G. Cassell ("Cassell") (together, "Plaintiffs"); (b) additional,
recently discovered facts in support
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613391.pdf
EFTA00611281Set 9
2009-12-2120p4,607w
Case No. 50 2009CA040800XXXXMB AG
JEFFREY EPSTEIN
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS,
individually, and L.M., individually,
Defendants.
EPSTEIN'S MOTION TO DISMISS EDWARDS'S COUNTERCLAIM
Plaintiff, JEFFREY ... moves to dismiss the 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 ... 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
EFTA00725968Set 9
30p8,528w
0408003OOOCMBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants,
DEFENDANT BRADLEY J. EDWARDS'S MOTION FOR FINAL SUMMARY JUDGMENT
Defendant, Bradley J. Edwards ... there is no genuine issue as to any material
facts and that Bradley J. Edwards, Esq. is entitled to summary judgment for all claims brought against
him in Plaintiff Jeffrey ... Complaint. Not only is there an absence of competent evidence to
demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly
demonstrates the propriety of every aspect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725968.pdf
EFTA00794277Set 9
2018-03-0221p6,249w
CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
/
COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION
FOR AN IN CAMERA INSPECTION OF 30 E-MAILS
Counter ... ruling from this Court that these 30 e-mails, which were improperly withheld by Edwards, an officer
of the court, on the false bases of irrelevancy, attorney-client privilege ... file this Motion and deliver the
accompanying sealed Memorandum by November 9, 2018. Edwards was instructed to deliver a
response sealed Memorandum by November 16, 2018.
2Epstein has reduced
https://www.justice.gov/epstein/files/DataSet%209/EFTA00794277.pdf
EFTA00808816Set 9
2009-12-0738p7,270w
FOURTH DISTRICT
JEFFREY EPSTEIN,
Petitioner,
-VS- CASE NO. 4D18-0787
SCOTT ROTHSTEIN,
DIZI J. EDWARDS, and
II ., ., and JANE DOE,
ntervenors,'
Respondents.
RESPONSE TO PETITION FOR WRIT OF CERTIORARI
SEARCY ... Avenue, Suite 350
West Palm Beach, FL 33401
Attorneys for Res ondent Bradley J. Edwards
' Petitioner did not include or Jane Doe in the caption of the Petition,
however, they ... TRIAL COURT DID NOT DEPART FROM THE 20-22
ESSENTIAL REQUIREMENTS OF LAW.
Edwards did not Waive the Right to Have the Claims Bifurcated 23-26
Bifurcation is Necessary
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA00592284Set 9
2009-12-0717p3,555w
FLORIDA
CASE NO.: 502009CA040800)OOCXMBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
ANSWER AND COUNTERCLAIM OF DEFENDANT, BRADLEY J. EDWARDS
Defendant, BRADLEY ... EDWARDS, individually, by and through his undersigned
attorneys files his Answer and Counterclaim to the Complaint filed by Plaintiff, JEFFREY
EPSTEIN, in the above-styled matter on December ... follows:
ANSWER
GENERAL ALLEGATIONS
1. Defendant, EDWARDS, denies the allegations contained in Paragraph 1 and
demands strict proof thereof.
2. Defendant, EDWARDS, admits the allegations contained in Paragraph
https://www.justice.gov/epstein/files/DataSet%209/EFTA00592284.pdf
EFTA00181472Set 9
2009-10-2038p23,922w
Phone: 561.8422820
Defendant . 6
7 On behalf of Plaintiff L.M.:
B BRADLEY J. EDWARDS. ESQUIRE
DEPOSITIO1 or wuRLLA Ramiro CARA L. HOLMES, ESQUIRE
Viratelt I
9 ROTHSTEIN ROSENFELDT ADLER
Tuesday ... JEFFREY EPSTEIN. LOUELLA RABUTO
6 Defendant 7
9 Related Cases: 8 BY MR. EDWARDS: 5 190
03-80232. 08.80380. 98-60381, 08-80994. s BY MR. MERMELSTEile ... DIRECT EXAMINATION 13 0 We've taken the deposition of another witness
14 MR. EDWARDS: Does anyone want to put on the 14 in this case, Alfredo Rodriguez
https://www.justice.gov/epstein/files/DataSet%209/EFTA00181472.pdf
EFTA00607567Set 9
2009-12-0716p3,558w
COUNTY, FLORIDA
CASE NO.: 502009CA0408003OCONBAG
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
ANSWER AND COUNTERCLAIM OF DEFENDANT. BRADLEY J. EDWARDS
Defendant, BRADLEY ... EDWARDS, individually, by and through his undersigned
attorneys files his Answer and Counterclaim to the Complaint filed by Plaintiff, JEFFREY
EPSTEIN, in the above-styled matter on December ... follows:
ANSWER
GENERAL ALLEGATIONS
1. Defendant, EDWARDS, denies the allegations contained in Paragraph 1 and
demands strict proof thereof.
2. Defendant, EDWARDS, admits the allegations contained in Paragraph
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607567.pdf
EFTA00603608Set 9
2015-01-06129p34,335w
CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE 15-000072
BRADLEY J. EDWARDS and
PAUL G. CASSELL,
Plaintiffs/Counterclaim Defendants,
vs.
ALAN M. DERSHOWITZ,
Defendant/Counterclaim Plaintiff.
DEFENDANT/COUNTERCLAIM PLAINTIFF ALAN ... entry of an Order that (a) overrules the objections asserted by Plaintiffs
BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") in response to
Dershowitz's First Set of Document ... Requests and First Set of Interrogatories; (b) compels
Edwards and Cassell to produce any and all documents responsive to Dershowitz's First Set of
Document Requests; and (c) compels Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA00603608.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
DISTRICT COURT OF APPEAL OF FLORIDA
FOURTH DISTRICT
CASE NO. 4D14-2282
BRADLEY J. EDWARDS,
Appellant,
v.
JEFFREY EPSTEIN,
Appellee.
MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT
The appellee, Jeffrey ... prosecution and abuse of
process claims filed against Epstein by the appellant, Bradley J. Edwards. The trial
judge relied in part upon the then binding precedent of Wolfe v. Foreman ... litigation privilege applies to causes of
action for malicious prosecution and abuse of process). Edwards appealed and is
challenging the final judgment solely as to the malicious prosecution claim
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA00793693Set 9
2018-03-0824p4,964w
Case No: 502009CA0408003OOOCMB AG
JEFFREY EPSTEIN,
Petitioner/Plaintiff,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Respondents/Defendants.
PETITION FOR WRIT OF CERTIORARI
On Review of a Non-Final Order ... Order entered
March 8, 2018' by the Honorable Donald Hafele, granting Respondent Bradley J.
Edwards' Motion for Separate Trials.''
By separate motion, Petitioner moves to consolidate this petition with ... Materials and to Seek
Other Appropriate Remedies (D.E. 1234), an Emergency Motion to Join Edwards'
Motion to Strike and for Related Relief (D.E. 1233), and an Unopposed Emergency
Motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793693.pdf
EFTA00808455Set 9
2010-09-0816p3,535w
Case No. 502009CA040800XXXXMB AG
JEFFREY EPSTEIN,
Petitioner/Plaintiff,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Respondents/Defendants.1
REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI
On Review ... unrelated issue. As such, they are not parties in
this certiorari proceeding, and Edwards has improperly captioned them as such on his
Response.
EFTA00808455
INTRODUCTION
Disappointingly, Bradley Edwards ("Edwards ... Petition as yet another
vehicle for false and misleading ad hominem attacks against Epstein. Edwards'
inaccurate and misleading factual and procedural recitation is typical of the smoke-
and-mirrors strategy
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808455.pdf
EFTA00585394Set 9
2010-03-2326p10,566w
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JUDGE: HAFELE
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
and BRADLEY J. EDWARDS,
individually.
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO
OVERRULE OBJECTIONS AND COMPEL DEFENDANT/COUNTER-PLAINTIFF
BRADLEY EDWARDS ... Procedure, hereby moves
this Court for entry of an order directing Defendant/Counter-Plaintiff Bradley J. Edwards
("Edwards") to respond to questions asked of him at his deposition taken on March ... Motion, Epstein states:
I \ 1 RODUCTION
On March 23, 2010, counsel for Epstein deposed Edwards (hereinafter "the first
EFTA00585394
deposition"). During that examination, Edwards refused to answer numerous questions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00585394.pdf