📄 Extracted Text (7,745 words)
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
VS.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
SECOND
AMENDED COUNTERCLAIM
Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges:
COUNT I-ABUSE OF PROCESS
1. This is an action for damages in an amount in excess of the minimum
jurisdictional limits of this Court.
2. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida,
and is an attorney licensed to practice in the State of Florida at all times material hereto.
3. Counter/defendant, EPSTEIN, is sui juris and is a resident of Palm Beach County,
Florida.
4. EPSTEIN is a convicted felon having entered into a plea agreement pursuant to
which he effectively conceded his having engaged in illicit sexual activity with a large number of
female children over an extended period of time in violation of both State and Federal criminal
laws.
EFTA00294244
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 2 of 13
5. EPSTEIN was sued civilly by a large number of his victims. Many of the cases
against him have been settled, and upon information and belief, federal law enforcement
agencies continue to investigate additional allegations of EPSTEIN'S serial abuse and
molestation of children; others remain pending. As a consequence, EPSTEIN continues to face
the potential of further criminal prosecution and huge civil judgments for both compensatory and
punitive damages in favor of many victims of his depraved criminal exploitation of children
including victims represented by EDWARDS.
6. In the face of overwhelming evidence of his guilt, EPSTEIN repeatedly asserted
his Fifth Amendment Right against self-incrimination and refused to answer any substantive
questions regarding his sexual exploitation of his minor victims. Lacking any substantive
defense to the claims against him, EPSTEIN sought to avoid his compensatory and punitive
liability and to deter cooperation in the ongoing criminal investigation by employing the
extraordinary financial resources at his disposal to intimidate his victims and their legal counsel
into abandoning their legitimate claims or resolving those claims for substantially less than their
just value.
7. In some circumstances, EPSTEIN's tactics have proven successful, while other
victims have thus far withstood this continued assault upon them and persisted in the prosecution
of their claims. EDWARDS' clients are among those who continued the prosecution of their
claims and the assertion of federal statutory rights afforded to them pursuant to the Federal
Crime Victims' Rights Act (CVRA).
EFTA00294245
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 3 of 13
8. While prosecuting the legitimate claims on behalf of his clients, EDWARDS has
not engaged in any unethical, illegal, or improper conduct nor has EDWARDS taken any action
inconsistent with the duty he has to vigorously represent the interests of his clients. EPSTEIN
has no reasonable basis to believe otherwise and has never had any reasonable basis to believe
otherwise.
9. Nevertheless, EPSTEIN filed civil claims against EDWARDS and EDWARDS'
client, L.M. for the sole purpose of further attempting to intimidate EDWARDS, L.M., and
others into abandoning or settling their legitimate claims for less than their just and reasonable
value. His sole purpose in both filing and prosecuting claims against EDWARDS was never the
stated purpose of collecting money damages from EDWARDS since EPSTEIN knew that he had
never suffered any damage as a consequence of any wrongdoing by EDWARDS. Nevertheless,
EPSTEIN filed knowingly baseless and unsupportable claims against EDWARDS and proceeded
to prosecute those baseless and unsupportable claims in order to divert EDWARDS from the
prosecution of EDWARDS' legitimate claims against EPSTEIN, to require EDWARDS to
expend time, energy and resources on his own defense, to embarrass EDWARDS and impugn his
integrity, and deter others with legitimate claims against EPSTEIN from pursuing those claims at
the risk of having to fend off similar assaults. EPSTEIN's real purpose was to put pressure on
EDWARD$, L.M., and other victims by publishing what amounts to nothing more than a highly
defamatory press release issued under the cloak of protection of the litigation privilege.
10. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had
ulterior motives and purposes in filing his unsupported and unsupportable claims. EPSTEIN'S
EFTA00294246
Edwards adv. Epstein
Case No.: 502009CA040800XXXXIABAG
Second Amended Counterclaim
Page 4 of 13
primary purpose in both filing and continuing to prosecute each of the claims against
EDWARDS was to inflict a maximum economic burden on EDWARDS in having to defend
against the spurious claims, to distract EDWARDS from the prosecution of claims against
EPSTEIN arising out of EPSTEIN'S serial abuse of minors, and ultimately to extort EDWARDS
into abandoning the claims he was prosecuting against EDWARDS.
The claims filed by EPSTEIN against EDWARDS included the following:
a. violation of F.S. §§772.101, et. seq.—
Florida Civil Remedies for Criminal Practices Act;
b. Florida RICO—"Racketeer Influenced and Corrupt Organization Act"
pursuant to F.S. §§895.01, et. seq.;
c. abuse of process;
d. fraud;
e. conspiracy to commit fraud.
12. EPSTEIN, in his Complaint, directly alleged that EDWARDS was a knowing
participant in a civil theft and criminal enterprise when EPSTEIN was well aware that there was
and is absolutely no evidence whatsoever to support such false assertions. Indeed, his Complaint
was replete with speculation, conjecture, and innuendo and was entirely devoid of factual
support for his spurious allegations. Indicative of his total disregard for the lack of any predicate
for his claims, EPSTEIN ignored the statutory requirement for written notice prior to the
initiation of a civil theft claim.
EFTA00294247
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMIIAG
Second Amended Counterclaim
Page 5 of 13
13. EPSTEIN knew at the time of the filing of the specified claims and throughout his
failed prosecution of those claims that he could not prosecute the claims to a successful
conclusion because:
a. they were both false and unsupported by any reasonable belief or
suspicion that they were true;
b. he had suffered no legally cognizable injury proximately caused by the
falsely alleged wrongdoing on the part of EDWARDS;
c. he had no intention of waiving his Fifth Amendment privilege against self-
incrimination in order to provide the relevant and material discovery that
would be necessary in the course of prosecuting the claims, (even if they
had any reasonable basis), and he knew that his prosecution would
consequently be barred by the sword-shield doctrine;
d. EDWARDS' conduct in the prosecution of claims against EPSTEIN could
not support the prosecution of a separate civil lawsuit against EDWARDS
because of the absolute protection of the litigation privilege.
14. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had
ulterior motives and purposes in filing his unsupported and unsupportable claims as previously
detailed in Paragraph 9.
15. EPSTEIN'S filing and prosecution of claims against EDWARDS recklessly and
purposely disregarded the lack of justification for each of the claims and EPSTEIN never had as
EFTA00294248
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 6 of 13
his primary purpose to establish what he did consider or reasonably could have considered to be
meritorious claims.
16. Each and every pleading filed by and on behalf of EPSTEIN in his prosecution of
every claim against EDWARDS, every motion, every request for production, every subpoena
issued, and every deposition taken as detailed on the docket sheet attached as Exhibit A was
intended with respect to EDWARDS solely and exclusively to advance EPSTEIN'S efforts at
extortion as previously detailed, and constituted a perversion of process after its initial service.
17. As a result of EPSTEIN's wrongful conduct as alleged, EDWARDS has suffered
and will continue to suffer damages including but not limited to injury to his reputation,
interference in his professional relationships, the loss of the value of his time required to be
diverted from his professional responsibilities, and the cost of defending against EPSTEIN's
spurious and baseless claims.
WHEREFORE, EDWARDS demands judgment against EPSTEIN for compensatory
damages, costs, and such other and further relief as the Court may deem appropriate under the
circumstances. Counter/plaintiff, EDWARDS, reserves the right to assert a claim for punitive
damages upon satisfying the applicable statutory prerequisites.
Counter/plaintiff, EDWARDS, further demands trial by jury.
COUNT II—MALICIOUS PROSECUTION
18. This is an action for damages in an amount in excess of the minimum
jurisdictional limits of this Court.
EFTA00294249
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 7 of 13
19. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida,
and is an attorney licensed to practice in the State of Florida at all times material hereto.
20. Counter/defendant, EPSTEIN, is sui juris and is a resident of Palm Beach County,
Florida.
21. EPSTEIN is a convicted felon having entered into a plea agreement pursuant to
which he effectively conceded his having engaged in illicit sexual activity with a large number of
female children over an extended period of time in violation of both Statc and Federal criminal
laws.
22. EPSTEIN was sued civilly by a large number of his victims. Many of the cases
against him have been settled, and upon information and belief, federal law enforcement
agencies continue to investigate additional allegations of EPSTEIN'S serial abuse and
molestation of children; others remain pending. As a consequence, EPSTEIN continues to face
the potential of further criminal prosecution and huge civil judgments for both compensatory and
punitive damages in favor of many victims of his depraved criminal exploitation of children
including victims represented by EDWARDS.
23. In the face of overwhelming evidence of his guilt, EPSTEIN repeatedly asserted
his Fifth Amendment Right against self-incrimination and refused to answer any substantive
questions regarding his sexual exploitation of his minor victims. Lacking any substantive
defense to the claims against him, EPSTEIN sought to avoid his compensatory and punitive
liability and to deter cooperation in the ongoing criminal investigation by employing the
extraordinary financial resources at his disposal to intimidate his victims and their legal counsel
EFTA00294250
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 8 of 13
into abandoning their legitimate claims or resolving those claims for substantially less than their
just value.
24. While prosecuting the legitimate claims on behalf of his clients, EDWARDS has
not engaged in any unethical, illegal, or improper conduct nor has EDWARDS taken any action
inconsistent with the duty he has to vigorously represent the interests of his clients. EPSTEIN
has no reasonable basis to believe otherwise and has never had any reasonable basis to believe
otherwise.
25. Nevertheless, EPSTEIN filed civil claims against EDWARDS and EDWARDS'
client, L.M. for the sole purpose of further attempting to intimidate EDWARDS, L.M., and
others into abandoning or settling their legitimate claims for less than their just and reasonable
value. His sole purpose in filing claims against EDWARDS was never the stated purpose
of
collecting money damages from EDWARDS since EPSTEIN knew that he had never suffered
any damage as a consequence of any wrongdoing by EDWARDS. Nevertheless, EPSTEIN filed
knowingly baseless and unsupportable claims against EDWARDS and proceeded to prosecute
those baseless and unsupportable claims in order to divert EDWARDS from the prosecution
of
EDWARDS' legitimate claims against EPSTEIN, to require EDWARDS to expend time, energy
and resources on his own defense, to embarrass EDWARDS and impugn his integrity, and deter
others with legitimate claims against EPSTEIN from pursuing those claims at the risk of having
to fend off similar assaults. EPSTEIN's real purpose was to put pressure on EDWARDS, L.M.,
and other victims by publishing what amounts to nothing more than a highly defamatory press
release issued under the cloak of protection of the litigation privilege.
EFTA00294251
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 9 of 13
26. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had
ulterior motives and purposes in filing his unsupported and unsupportable claims. EPSTEIN'S
primary purpose in filing each of the claims against EDWARDS was to inflict a maximum
economic burden on EDWARDS in having to defend against the spurious claims, to distract
EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEIN'S serial
abuse of minors, and ultimately to extort EDWARDS into abandoning the claims he was
prosecuting against EDWARDS.
27. The claims filed by EPSTEIN against EDWARDS were the following:
a. violation of F.S. §§772.10I, et. seq.—
Florida Civil Remedies for Criminal Practices Act;
b. Florida RICO—"Racketeer Influenced and Corrupt Organization Act"
pursuant to F.S. §§895.01, et. seq.;
c. abuse of process;
d. fraud;
e. conspiracy to commit fraud.
28. EPSTEIN, in his Complaint, directly alleged that EDWARDS was a knowing
participant in a civil theft and criminal enterprise and that he had conspired to and did engage in
a fraud against EPSTEIN when EPSTEIN was well aware that there was and is absolutely no
evidence whatsoever to support such false assertions. Indeed, his Complaint was replete with
speculation, conjecture, and innuendo and was entirely devoid of factual support for his spurious
allegations. Indicative of his total disregard for the lack of any predicate for his claims,
EFTA00294252
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 10 of 13
EPSTEIN ignored the statutory requirement for written notice prior to the initiation of a civil
theft claim.
29. EPSTEIN knew at the time of the filing of the specified claims and throughout his
failed prosecution of those claims that he could not prosecute the claims to a successful
conclusion because:
a. they were both false and unsupported by any reasonable belief or
suspicion that they were true;
b. he had suffered no legally cognizable injury proximately caused by the
falsely alleged wrongdoing on the part of EDWARDS;
c. he had no intention of waiving his Fifth Amendment privilege against self-
incrimination in order to provide the relevant and material discovery that
would be necessary in the course of prosecuting the claims, (even if they
had any reasonable basis), and he knew that his prosecution would
consequently be barred by the sword-shield doctrine;
d. EDWARDS' conduct in the prosecution of claims against EPSTEIN could
not support the prosecution of a separate civil lawsuit against EDWARDS
because of the absolute protection of the litigation privilege.
30. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had
ulterior motives and purposes in filing his unsupported and unsupportable claims as previously
detailed in Paragraph 25.
EFTA00294253
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page I I of 13
31. EPSTEIN'S filing and prosecution of claims against EDWARDS recklessly and
purposely disregarded the lack of justification for each of the claims and EPSTEIN never had as
his primary purpose to establish what he did consider or reasonably could have considered to be
meritorious claims.
32. After unsuccessful efforts to defend and amend his maliciously filed and
prosecuted claims over a period of almost two years, EPSTEIN abandoned each of the claims
described in Paragraph 27 except for an ongoing effort to salvage his abuse of process claim.
That abandonment brings to successful conclusion EDWARDS' defense against each of the
other abandoned claims and constitutes a specific bona fide termination in EDWARDS' favor of
the prior prosecution of each abandoned claim.
33. As a result of EPSTEIN's wrongful conduct as alleged, EDWARDS has suffered
and will continue to suffer damages including but not limited to injury to his reputation,
interference in his professional relationships, the loss of the value of his time required to be
diverted from his professional responsibilities, and the cost of defending against EPSTEIN's
spurious and baseless claims.
WHEREFORE, EDWARDS demands judgment against EPSTEIN for compensatory
damages, costs, and such other and further relief as the Court may deem appropriate under the
circumstances. Counter/plaintiff, EDWARDS, reserves the right to assert a claim for punitive
damages upon satisfying the applicable statutory prerequisites.
Counter/plaintiff, EDWARDS, further demands trial by jury.
EFTA00294254
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 12 of 13
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
Fax and U.S. Mail to all counsel on the attached l t, this 4.7 day of November, 2011.
Jack arila
Florida ar No.: 169440
S rc Denney Scarola Barnhart & Shipley, P.A.
Palm Beach Lakes Boulevard
.st Palm Beach, Florida 33409
hone: (561) 686-6300
Fax: (561) 383-9451
Attorneys for Bradley J. Edwards
EFTA00294255
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Second Amended Counterclaim
Page 13 of 13
COUNSEL LIST
Jack A. Goldberger, Esquire
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue South, Suite 1400
West Palm Beach, FL 33401
Phone: (561) 659-8300
Fax: (561) 835-8691
Fanner, Jaffe, Weissing, Edwards, Fistos &
Lehrman, PL
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954) 524-2820
Fax: (954) 524-2822
Marc S. Nurik, Esquire
Law Offices of Marc S. Nurik
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954) 745-5849
Fax: (954) 745-3556
Joseph L. Ackerman, Jr., Esquire
Fowler White Burnett, P.A.
901 Phillips Point West
777 S Flagler Drive
West Palm Beach, FL 33401-6170
Phone: (561) 802-9044
Fax: (561) 802-9976
EFTA00294256
- Not an Official Document Page 1 of 67
Report Selection Criteria
Case ID: 502009CA040800XXXXMB
Docket Start Date:
Docket Ending Date:
Case Description
Case ID: 502009CA040800XXXXMB
Case Caption: JEFFREY EPSTEIN V SCOTT ROTHSTEIN
Division: AG -CROW
Filing Date: Monday , December 07th, 2009
Court: CA - CIRCUIT CIVIL
Location: MB - MAIN BRANCH
Jury: Y-Jury
Type: OC - OTHER CIRCUIT
Status: PE - PENDING
Related Cases
No related cases were found.
Case Event Schedule
No case events were found.
Case Parties
Seq Expn
Assoc
Date
PLAINTIFF @2075728 EPSTEIN, JEFFREY Aliases:
11- ATTORNEY 0224162 CRITTON JR , ESQ, Aliases: none
JUN- ROBERT DEWEESE
2010
DEFENDANT @2075729 ROTHSTEIN, SCOTT Aliases:
DEFENDANT (2075730 EDWARDS, Aliases:
BRADLEY J
EXHIBIT A
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EFTA00294257
- Not an Official Document Page 2 of 67
5 10- DEFENDANT O)2075731 LM Aliases: none
AUG-
2010
JUDGE AG CROW, JUDGE Aliases: none
DAVID
ATTORNEY 0169440 SCAROLA , ESQ, Aliases: none
JACK
ATTORNEY 0914444 FARMER, ESQ, Aliases: none
GARY
9
1 ATTORNEY 0195677 SANCHEZ, LILLY
ANN
Aliases: none
10 ATTORNEY 0235954 ACKERMAN , ESQ, Aliases: none
JOSEPH L
11 ATTORNEY 0599298 [ADLER , ESQ, Aliases: none
RUSSELL S
Docket Entries
Docket
Docket Type Book and Page No. Attached To:
100000 - ADDITIONAL COMMENTS
[Filing Date: 07-DEC-2009
Filing Party:
Disposition Amount:
Docket Text: none.
800FF - CAFF
Filing Date: 07-DEC-2009
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EFTA00294258
- Not an Official Document Page 3 of 67
Filing Party: IIEPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
PE - PENDING
Filing Date: 07-DEC-2009
Filing Party:
Disposition Amount:
Docket Text: none.
RCPT - RECEIPT FOR PAYMENT
Filing Date: 07-DEC-2009
Filing Party: EPSTEIN, JEFFREY Ii
Disposition Amount:
Docket Text: A Payment of -$30.00 was made on receipt CAMB363437.
1 CMP - COMPLAINT
Filing Date: 07-DEC-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
2 CCS - CIVIL COVER SHEET
Filing Date: 07-DEC-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
3 1SMIS - SUMMONS ISSUED
Filing Date: 07-DEC-2009
Filing Party: L M,
Disposition Amount:
Docket Text: SM-09-232330
4 SMIS - SUMMONS ISSUED
Filing Date: 07-DEC-2009
Filing Party: ROTHSTEIN, SCOTT
Disposition Amount:
Docket Text: SM-09-232331
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EFTA00294259
- Not an Official Document Page 4 of 67
5 II SMIS - SUMMONS ISSUED
Filing Date: 07-DEC-2009
Filing Party: IEDWARDS, BRADLEY J
Disposition Amount:
Docket Text: SM-09-232332
6 SMIS - SUMMONS ISSUED
Filing Date: 07-DEC-2009
Filing Party: )ROTHSTEIN, SCOTT
Disposition Amount:
Docket Text: NOT USED SM-09-232389
7 SMIS - SUMMONS ISSUED
Filing Date: 07-DEC-2009
Filing Party: IROTHSTEIN, SCOTT
Disposition Amount:
I Docket Text: SCOTT ROTHSTEIN SM-09-232390
RCPT - RECEIPT FOR PAYMENT
(Filing Date: 08-DEC-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: A Payment of -$401.00 was made on receipt CAMB363514.
RCPT - RECEIPT FOR PAYMENT
Filing Date: 08-DEC-2009
Filing Party:
Disposition Amount:
Docket Text: A Payment of -$10.00 was made on receipt CAMB363732.
SRTN - SERVICE RETURN
(ATTACHED)
Filing Date: 11-DEC-2009
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
SRTN - SERVICE RETURN
(ATTACHED)
Filing Date: 11-DEC-2009
1
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EFTA00294260
- Not an Official Document Page 5 of 67
Filing Party: III- M,
Disposition Amount:
Docket Text: none.
SRTN - SERVICE RETURN
(ATTACHED)
Filing Date: 14-DEC-2009
Filing Party: ROTHSTEIN, SCOTT
Disposition Amount:
Docket Text: SERVED
RCPT - RECEIPT FOR PAYMENT
Filing Date: 21-DEC-2009
Filing Party:
Disposition Amount:
Docket Text: A Payment of -$395.00 was made on receipt CAMB367609.
8 ANS - ANSWER
Filing Date: 21-DEC-2009
Filing Party: EDWARDS, BRADLEY J J
Disposition Amount:
Docket Text: AND COUNTERCLAIM
9 TANS -ANSWER
Filing Date: 21-DEC-2009
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: & COUNTERCLAIM . . .
10 I MSTR - MOTION TO STRIKE
Filing Date: 28-DEC-2009
Filing Party: L M,
Disposition Amount:
Docket Text: Inone.
11 I ANAD - ANSWER & AFFIRMATIVE
DEFENSES
Filing Date: 28-DEC-2009
Filing Party: L M,
Disposition Amount:
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EFTA00294261
- Not an Official Document Page 6 of 67
Docket Text: Inone.
15 MDFT - MOTION FOR DEFAULT
Filing Date: 31-DEC-2009
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: AGAINST DFT SCOTT ROTHSTEIN
12 MOT - MOTION
Filing Date: 12-JAN-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: OFOR A MORE DEFINITE.
13 RADF - REPLY TO AFFIRMATIVE
DEFENSES
Filing Date: 12-JAN-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
16 I NOH - NOTICE OF HEARING
Filing Date: 14-JAN-2010
Filing Party:
Disposition Amount:
Docket Text: none.
17 I RNOH - RE-NOTICE OF HEARING
Filing Date: 19-JAN-2010
Filing Party:
Disposition Amount:
Docket Text: none.
14 DFT-DEFAULT
Filing Date: 21-JAN-2010
Filing Party: ROTHSTEIN, SCOTT
Disposition Amount:
Docket Text: none.
18 NCAN - NOTICE OF CANCELLATION
Filing Date: [25-JAN-2010
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EFTA00294262
- Not an Official Documcnt Page 7 of 67
Filing Party: ICRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: OF HEARING
19 LORD - ORDER
Filing Date: 26-JAN-2010
Filing Party:
Disposition Amount:
ON MOT OF COUNTER-DFT FOR MORE DEFINITE STATEMENT
Docket Text:
AND MOT TO DISMISS, DENIED. D CROW.
20 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 04-FEB-2010
Filing Party: 1 CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: none.
21 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 08-FEB-2010
Filing Party:
Disposition Amount:
Docket Text: none.
22 IMOT- MOTION
Filing Date: 17-FEB-2010
Filing Party: ROTHSTEIN, SCOTT
Disposition Amount:
Docket Text: TO SET ASIDE DEFAULT
23 MDIS - MOTION TO DISMISS
Filing Date: 26-FEB-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: EDWARDS' COUNTERCLAIM
24 NOH - NOTICE OF HEARING
Filing Date: 26-FEB-2010
Filin Party: EPSTEIN, JEFFREY
Disposition Amount:
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EFTA00294263
- Not an Official Document Page 8 of 67
Docket Text: 3-9-10 AT 8:45 AM
25 NOH - NOTICE OF HEARING
Filing Date: 01-MAR-2010
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: 3-2-10 AT 8:45 AM
32 MDFT - MOTION FOR DEFAULT
Filing Date: 01-MAR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: AGAINST JEFFREY EPSTEIN
26 MSTR - MOTION TO STRIKE
Filing Date: 02-MAR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: MOTION TO DISMISS AND IMPOSE SANCTIONS
27 RNOH - RE-NOTICE OF HEARING
Filing Date: 02-MAR-2010
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: none.
128 I NOH - NOTICE OF HEARING
Filing Date: 02-MAR-2010
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
Docket Text: _ none.
29 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 03-MAR-2010
'Filing Party: L M,
Disposition Amount:
Docket Text: CROSS
30 ORD - ORDER
Filing Date: 04-MAR-2010
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EFTA00294264
- Not an Official Document Page 9 of 67
'Filing Party: II
Disposition Amount:
ON MOTION TO STRIKE, DISMISS AND IMPOSE
Docket Text:
SANCTIONS...SEE ORDER DCROW
31 ORD - ORDER
Filing Date: 09-MAR-2010
Filing Party:
Disposition Amount:
Docket Text: ON MOTIO TO SET ASIDE DEFAULT:D CROW
33 MDFT - MOTION FOR DEFAULT
Filing Date: 11-MAR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: PLEADING WAS FILED (NO ENVELOPE PROVIDED)**
34 NOH - NOTICE OF HEARING
Filing Date: 11-MAR-2010
Filing Party: JCRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: 4-30-10 AT 3:30 PM
35 ANS - ANSWER
Filing Date: 16-MAR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO COUNTERCLAIM
36 RADF - REPLY TO AFFIRMATIVE
DEFENSES
Filing Date: 16-MAR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
37 REQP - REQUEST TO PRODUCE
Filing Date: 18-MAR-2010
Filing Party: (EDWARDS, BRADLEY J
Disposition Amount:
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Docket Text: Ilnone.
38 MOT - MOTION
Filing Date: 29-MAR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
FOR JUDGMENT OR ALTERNATIVE MOTION FOR SUMMARY
Docket Text: JUDGMENT
[39 NOJT - NOTICE OF JURY TRIAL
Filing Date: 05-APR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: r UP 4/7/10**
40 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 05-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 'VIDEO OF SCOTT ROTHSTEIN ON 4-15-10 AT 10 AM
41 r NOS - NOTICE OF SERVICE
Filing Date: 07-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: JFIRST SET OF INTERROGATORIES
42 INOH - NOTICE OF HEARING
Filing Date: 07-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: 5-11-10 AT 8:15 AM
43 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 07-APR-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: VIDEO OF MICHAEL FISTEN & RICHARD FANDRY
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4 REQP - REQUEST TO PRODUCE
Filing Date: 13-APR-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: TO EDWARDS
4 MOT - MOTION
Filing Date: 13-APR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: PURSUANT TO F.S. 57.105
46 NOH - NOTICE OF HEARING
Filing Date: 115-APR-2010
Filing Party: FARMER, ESQ, GARY
Disposition Amount:
Docket Text: 14-19-10 AT 8:45 AM
I
47 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 15-APR-2010
Filing Party: L M,
Disposition Amount:
Docket Text: none.
48 I OSJT - ORDER SETTING JURY TRIAL
Filing Date: 15-APR-2010
Filing Party:
Disposition Amount:
Docket Text: 10-15-10 AT 9 AM. D CROW
49 NOH - NOTICE OF HEARING
Filing Date: 16-APR-2010
Filing Party:
Disposition Amount:
EPSTEIN, JEFFREY i
Docket Text: 4-22-10 AT 8:45 AM
50 MSTR - MOTION TO STRIKE
Filing Date: 16-APR-2010
Filing Party: EPSTEIN, JEFFREY
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Disposition Amount: i
Docket Text: AFFIDAVIT OF SCOTT ROTHSTEIN
51 ORD - ORDER
Filing Date: 19-APR-2010
Filing Party:
Disposition Amount:
Docket Text: ON MOTION FOR PROTECTIVE ORDER: GRANTED. D CROW
52 NOTD - NOTICE OF TAKING
DEPOSITION
Filing Date: 19-APR-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: OF HERBERT STETTIN 5-19-10 AT 4 PM
53 MOT - MOTION
Filing Date: 21-APR-2010
Filing Party: IEPSTEIN, JEFFREY
Disposition Amount:
FOR ENLARGEMENT OF TIME TO RESPOND TO REQUEST TO
Docket Text:
PRODUCE
54 MOT - MOTION
Filing Date: 21-APR-2010
Filing Party: L M,
Disposition Amount:
Docket Text: PURSUANT TO F.S. 57.105
55 ORD - ORDER
Filing Date: 22-APR-2010
Filing Party:
Disposition Amount:
ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN:
Docket Text:
DENIED. D CROW
56 I NOH - NOTICE OF HEARING
Filing Date: 23-APR-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: 5-5-10 AT 8:45 AM
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57 NOH - NOTICE OF HEARING
Filing Date: 26-APR-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: 4-30-10 AT 3:30 PM
58 I NOAP - NOTICE OF APPEARANCE
Filing Date: 27-APR-2010
Filing Party:
Disposition Amount:
Docket Text:
CO
COUNSEL OBO PLTF JEFFREY EPSTEIN FILED BY JACK A
GOLDBERGER ESQ
r59 I RQCP - REQUEST FOR COPIES
Filing Date: 27-APR-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
60 RPRS - REPLY/RESPONSE
Filing Date: 03-MAY-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: & SUPPORTING LEGAL AUTHORITIES IN OPPOSITION. . .
61 MCMP - MOTION TO COMPEL
Filing Date: 10-MAY-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: BRADLEYY EDWARDS TO APPEAR FOR FOLLOW UP DEPO
62 ORD - ORDER
Filing Date: 11-MAY-2010
Filing Party:
Disposition Amount:
ON EPSTEIN MOTION FOR JUDGMENT ON THE PLEADINGS .. .
Docket Text:
DCROW
63 NOF - NOTICE OF FILING
Filing Date: lit -MAY-2010
i
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Filing Party: 'EPSTEIN, JEFFREY
Disposition Amount:
CORRECTED EXHIBIT D AS CITED IN PLTF MOTION TO
Docket Text:
COMPEL. .
64 I NOH - NOTICE OF HEARING
Filing Date: 11-MAY-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
5/20/10 8:45 AM EPSTEIN MOTION TO COMPEL BRADLEY
Docket Text:
EDWARDS TO APPEAR FOR FOLLOWUP DEPO
65 RESP - RESPONSE TO:
Filing Date: 12-MAY-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: REQ FOR PRODUCTION DTD 4/12/10
66 NOS - NOTICE OF SERVICE
Filing Date: 12-MAY-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: IOF DFT EDWARDS ANSWERS TO PLTF 1ST INTERRS
67 NOF - NOTICE OF FILING
Filing Date: 14-MAY-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: ORIG JURAT TO ANSWERS . . . .
68 NCAN - NOTICE OF CANCELLATION
Filing Date: 20-MAY-2010
Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE
Disposition Amount:
Docket Text: OF HEARING
69 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 20-MAY-2010
Filing Party:
Disposition Amount:
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Docket Text: II(BANKRUPTCY TRUSTEE)
70 JAGOR - AGREED ORDER
Filing Date: 21-MAY-2010
Filing Party:
Disposition Amount:
ON EPSTEINS MOTION FOR ENLARGEMENT OF TIME TO
Docket Text:
RESPOND TO EDWARDS REQUEST TO PRODUCE
71 MOT - MOTION
Filing Date: I[25-MAY-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: ITO POSTPONE HEARING
72 NOH - NOTICE OF HEARING
Filing Date: 25-MAY-2010
Filing Party:
Disposition Amount:
Docket Text: 01-JUN-10
73 RESP - RESPONSE TO:
Filing Date: 27-MAY-2010
Filing Party: I EPSTEIN, JEFFREY
Disposition Amount:
IN OPPOSITION TO MOTION TO SET ASIDE DEFAULT
Docket Text:
W/ATTACHMENTS
74 RRTP - RESPONSE TO REQ TO
PRODUCE
Filing Date: 27-MAY-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
75 ORD - ORDER
Filing Date: 01-JUN-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
ON EPSTEINS MOTION TO POSTPONE THE 6/4/10 HEARING IS
Docket Text:
GRANTED. D CROW
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76 i REQP - REQUEST TO PRODUCE
Filing Date: 03-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: (SUPPLEMENTAL) OF DEFT EPSTEIN
77 CNS - CONSENT
Filing Date: 11-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: [none.
78 ORD - ORDER
Filing Date: 11-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: ON SUBSTITUTION OF COUNSEL DCROW
79 STIP - STIPULATION
Filing Date: 11-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: & SUBSTITUTION OF COUNSEL
80 MCMP - MOTION TO COMPEL
Filing Date: 17-JUN-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: COMPLETE RESONSE TO REQ TO PRODUCE IJ
81 NOH - NOTICE OF HEARING
Filing Date: 17-JUN-2010
Filing Party: SCAROLA , ESQ, JACK
Disposition Amount:
6/29/10 8:45 AM DFT EDWARDS MOTION TO COMPEL PLTF
Docket Text:
EPSTEIN TO RESPOND TO REQ . . .
82 NOH - NOTICE OF HEARING
Filing Date: 21-JUN-2010
Filing Party:
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'Disposition Amount:
Docket Text: 6/28/10 8:45 AM MOTION TO COPEL PRODUCTION OF DOCS. . .
83 MCMP - MOTION TO COMPEL
Filing Date: 21-JUN-2010
Filing Party: EPSTEIN, JEFFREY
Disposition Amount:
Docket Text: PRODUCTION OF DOCS FROM BANKRUPTCY. . .
84 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 22-JUN-2010
Filing Party: L M,
Disposition Amount:
Docket Text: none.
85 MFPO - MOTION FOR PROTECTIVE
ORDER
Filing Date: 25-JUN-2010 _
Filing Party:
Disposition Amount:
Docket Text: (BANKRUPTCY TRUSTEE SUPPLEMENTAL)
86 MOT - MOTION
Filing Date: I25-JUN-2010
Filing Party: I
Disposition Amount:
Docket Text: !OF HERBERT STETTIN-FOR PROTECTIVE ORDER
87 NOH - NOTICE OF HEARING
Filing Date: 125-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: JUNE 28 2010
88 NOT - NOTICE
Filing Date: 25-JUN-2010
Filing Party:
Disposition Amount:
Docket Text: JOINDER
•
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89 [XLT - EXHIBIT LIST
Filing Date: 30-JUN-2010
Filing Party: JEPSTEIN, JEFFREY
Disposition Amount:
Docket Text: none.
90 I WLIS - WITNESS LIST
Filing Date: 30-JUN-2010
Filing Party: EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: none.
91 I NOH - NOTICE OF HEARING
Filing Date: 01-JUL-2010
Filing Party:
Disposition Amount:
Docket Text: none.
92 NOH - NOTICE OF HEARING
Filing Date: M.-JUL-2010
Filing Party:
Disposition Amount:
8/10/10 8:45 AM PLTF MOTION TO COMPEL BRADLEY EDWARDS
Docket Text:
TO APPEAR. . .
93 I_RERQ - RESPONSE TO REQ FORT
ADMISSION
Filing Date: j 07-JUL-2010
Filing Party: — I EDWARDS, BRADLEY J
Disposition Amount:
Docket Text: (1ST)
94 NOH - NOTICE OF HEARING
_....r
Filing Date: 12-JUL-2010
Filing Party:
Disposition Amount:
8/3/10 8:45 AM PLTF MOTION TO ENLARGE TIME TO SERVE
Docket Text:
WITNESS & EXHIBIT LIST . . .
95 NOS - NOTICE OF SERVICE
I
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[Filing Date: II12-JUL-2010
Filing Party: [EPSTEIN, JEFFREY
ℹ️ Document Details
SHA-256
0fa5d8c77b21c164fee521620866636056db22e47fa9d42bbcf1e9c050dd1eb0
Bates Number
EFTA00294244
Dataset
DataSet-9
Document Type
document
Pages
47
Comments 0