EFTA01112467.txt

"Bradley Edwards has not, and cannot, prove all of the essential elements of either cause of action he asserts against Epstein"

"electronic communication from Cara Holmes to Bradley Edwards dated July 29, 2009 (I think our best bet is to go after those close to Epstein.)"

"See Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson"

"the allegations in Epstein's lawsuit against Edwards, coupled with the irrefutable facts surrounding the underlying Epstein Cases"

"Epstein had the requisite cause, and a good faith basis upon which to file suit against Rothstein and Edwards"

"Tonja Haddad Coleman, Esq. ... Attorneys for Epstein"

"Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A."

"Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman"

"Plaintiff/Counter-Defendant Jeffrey Epstein respectfully requests that the Court grant his Motion for Summary Judgment."

"In December 2009, Epstein filed suit against Scott Rothstein (Rothstein) and Bradley J. Edwards (Edwards)"

"In December 2009, Epstein filed suit against Scott Rothstein (Rothstein) and Bradley J. Edwards (Edwards)"

"Edwards was a partner at Rothstein Rosenfeld Adler (RRA) from April 2009 through November 2009"

"misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm"

"Edwards has stated two causes of action against Epstein: Abuse of Process and Malicious Prosecution"

"Edwards was the lead counsel and the supervising attorney over each of the Epstein Cases used to lure investors and fund the Ponzi scheme"

"the law firm of Conrad Scherer very publicly filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et at v. Scott W. Rothstein"

"prosecution of every claim against EDWARDS, every motion, every request for production, every subpoena issued, and every deposition taken as detailed "

"Edwards solely bases his cause of action for Abuse of Process upon [ejach and every pleading filed by and on behalf of EPSTEIN"

"Epstein v. Rothstein, et al."

"See Edwards's Fourth Amended Counterclaim, paragraph 16"

"Edwards at the time that Edwards was a partner at RRA and the lead attorney on the Epstein Cases."

"Information repeatedly references RRA as the Enterprise with which Rothstein and his co-conspirators were associated and by which they were employed."

"On December 1, 2009... the Information against Scott Rothstein was filed by the Federal government. The thirty-seven (37) page Information included al"

"He is serving a fifty (50) year sentence."

"Epstein's private jet... planes, and other items of substantial value purportedly owned by Epstein."

"as soon as Edwards arrived at RRA, Edwards and his partners set and/or took depositions"

"Finally, while Epstein's suit was pending against Edwards, Scott Rothstein was deposed."

"Edwards's sole basis for his cause of action for Abuse of Process against Epstein is each and every pleading filed by and on behalf of EPSTEIN"

"EPSTEIN in his prosecution of every claim against EDWARDS, every motion, every request for production, every subpoena issued"

"Plaintiff on Bradley Edwards in this case. See Answers to Interrogatories filed June 10, 2011"

"Edwards stated: every pleading, motion, notice and discovery request served by the Plaintiff on Bradley Edwards in this case. See Answers to Interroga"

"Edwards filed a two hundred thirty-four (234) page, one fifty-six (156) count federal complaint against Epstein on behalf of a plaintiff, LM"

"the case Epstein voluntarily dismissed without prejudice, and which Epstein could re-file at any time"

"utilized funds obtained through the Ponzi scheme to supplement and support the operation and activities of RRA... to fund salaries and bonuses... in o"

"Rothstein used RRA's representation in the Epstein case to pursue issues and evidence unrelated to the underlying litigation but which was potentially"

"While Epstein's case was pending against Edwards. the Razorback case settled for approximately $170 million dollars."

"the Florida Bar had commenced investigations into over one-half of the attorneys (49 of 70) employed by RRA"

"Just because of the way I knew Brad and socialized with him, I did not know that he was at that level"

"high-profile witnesses onboard Epstein's private jet where some of the alleged sexual assaults took place"

"wealthy and influential friends of Epstein's who were identified to the Ponzi scheme investors; such as former President Bill Clinton"

"wealthy and influential friends of Epstein's... such as former President Bill Clinton, Donald Trump"

"wealthy and influential friends of Epstein's... Donald Trump, and David Copperfield"

"the events giving rise to Edwards's two purported claims against Epstein occurred solely in the conduct of the litigation, just as occurred in the Wol"