EFTA00597791

1)
8. 
In the Spring of 2009 (approximately April), I joined the law firm of Rothstein, 
Rosenfeldt and Adler, P.A. ("RRA"). I brought my existing clients with me when I 
joined RRA, including L.M., E.W., and Jane Doe. When I joined the firm, i was not 
aware that Scott Rothstein was nmnin' g a Ponzi scheme at RRA. Had i known such a 
Ponzi scheme was in place, I would never have joined RRA. 
9. 
I am now aware that it has been alleged that Scott Rothstein made fraudulent 
presentations to investors about the lawsuits that I had filed on behalf of my clients 
against Epstein and that it has been alleged that these lawsuits were used to fraudulently 
lure investors into 
Pot= scheme. I never met a single investor, had no part 
in any such presentations and had no knowledge any such fraud was occurring. If these 
allegations are true, 1 had no knowledge that any such fraudulent presentations were 
occurring and no knowledge of any such improper use of the case files. 
10. Epstein's Complaint against me alleges that Rothstein made false statements about 
cases filed against Epstein, i.e., that RRA had 50 anonymous females who had filed suit 
against Epstein; that Rothstein sold an interest in personal injury lawsuits, reached 
agreements to share attorneys fees with non-lawyers, paid clients "up front" money; and 
that he used the judicial process to further his Ponzi scheme. If Rothstein did any of 
these things, I had no knowledge of his actions. Because I maintained close contact 
with my clients, EW, LM and Jane Doe, and Scott Rothstein never met any of them, I 
know for certain that none of my clients were paid "up front" money by anyone. 
11. Epstein alleges that I attempted to take the depositions of his "high profile friends and 
acquaintances" for no legitimate litigation purpose. This is untrue, as all of my actions 
in representing L.M., E.W., and Jane Doe were aimed at providing them effective 
representation in their civil suits. With regard to Epstein's Mends, through documents 
and information obtained in discovery and other means of investigation, I learned that 
Epstein was sexually molesting minor girls on a daily basis and had been for many 
years. I also learned the =surprising fact that he was molesting the girls in the privacy 
of his mansion in West Palm Beach, meaning that locating witnesses to corroborate 
their testimony would be difficult to find. I also learned, from the course of the 
litigation, that Epstein and his lawyers were constantly attacking the credibility of the 
girls, that Epstein's employees were all represented by lawyers who apparently were 
paid for (directly or indirectly) by Epstein, that co-conspirators whose representation 
was also apparently paid for by Epstein were all taking the Fifth (like Epstein) rather 
than provide information in discovery. For example, I was given reason to believe that 
Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, 
Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyers 
paid for by Epstein. Because Epstein and the co-conspirators in his child molestation 
criminal enterprise blocked normal discovery avenues, I needed to search for other 
ordinary approaches to strengthen the cases of my clients. Consistent with my training 
and experience, these other ordinary approaches included finding other witnesses who 
could corroborate allegations of sexual abuse of my clients or other girls. Some of these 
witnesses were friends of Epstein. Given his social status, it also turned out that some 
of his friends were high-profile individuals. 
EFTA00597851

12. In light of information I received suggesting that British socialite Ghislaine Maxwell, 
former girlfriend and long-time friend of Epstein's, was involved in managing Epstein's 
affairs and companies I had her served for deposition for August 17, 2009. (Deposition 
Notice attached to Statement of Undisputed Facts as Exhibit BB). Maxwell was 
represented by Brett Jaffe of the New York firm of Cohen and Greaser, and I 
understood that her attorney was paid for (directly or indirectly) by Epstein. She was 
reluctant to give her deposition, and I tried to work with her attorney to take her 
deposition on terms that would be acceptable to both sides. 
Her attorney and I 
negotiated a confidentiality agreement, under which Maxwell agreed to drop any 
objections to the deposition. Maxwell, however, still avoided the deposition. On June 
29, 2010, one day before I was to fly to NY to take 
deposition, her attorney 
informed me that 
mother was deathly ill and Maxwell was consequently 
flying to England with no intention of 
• 
and certainly would not return to the 
United Itates before the conclusion of Jane 
trial period (August 6, 2010). 
Despite that assertion, I later learned that Ghislaine Maxwell was in fact in the country 
on approximately ni
t 2010, as she attended 4e wedding of Chelsea Clinton 
(former President 
daughter) and was captured in a photograph taken for US 
Weekly magazine. 
13. Epstein alleges that there was something improper in the fact that I notified him that I 
intended to take Donald 
deposition in the civil suits against him. Trump was 
properly noticed because: (a) after review of the message pads confiscated from 
Epstein's home, the legal and investigative team assisting my clients learned that Trump 
called Epstein's West Palm Beach mansion on several occasions during the time period 
most relevant to my clients' complaints; (b) Trump was quoted in a Vanity Fair article 
about Epstein as saying "I've known Jeff for fifteen years. Terrific guy." '1M a lot 
of fun to be with. It is even said that he likes beautiful women as much as I do, and 
many of them are on the younger side. No doubt about it — Jeffrey enjoys his social 
life." Jeffrey Epstein: International Moneyman of Mystery; 
pals with a passel of 
Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite 
Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, 
Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the world 
began to wonder who he is. By Landon Thomas Jr.; (c) I learned through a source 
that Trump banned Epstein from his Maralago Club in West Palm Beach because 
Epstein sexually assaulted an underage girl at the club; (d) Jane Doe No. 1021 
complaint alleged that Jane Doe 102 was initially approached at 
Maralago by 
Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) 
Mark Epstein (Jeffrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's 
plane with him (the same plane that Jane Doe 102 alleged was used to have sex with 
underage girls) deposition of Mark Epstein, September 21, 2009 at 48-50; (f) Trump 
visited Epstein at his home in Palm Beach — the same home where Epstein abused 
minor girls daily; (g) Epstein's phone directory from his computer contains 14 phone 
numbers for Donald Trump, including emergency numbers, car numbers, and numbers 
to 
security guard and houseman. Based on this information, I believed that 
EFTA00597852

(-) 
Trump might have relevant information to provide in the cases against Jeffrey Epstein 
and accordingly provided notice of a possible deposition. 
14. Epstein alleges that there was something improper in the fact that I notified hint that I 
intended to take Alan 
deposition in the civil suits against him. Dershowitz 
was properly noticed because: (a) Dershowitz has been friends with Epstein for many 
years; (b) in one news article Dershowitz comments that, "I'm on my 20th book... The 
only person outside of my immediate family that I send drafts to is Jeffrey" The 
Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Work, Vanity 
Fair; (c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed at 
Epstein's house during the years most relevant to my clients; (d) Rodriguez testified 
that Dershowitz was at Epstein's house at times when underage females where there 
being molested by Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426-
aili
Dershowitz was reportedly involved in persuading the Palm Beach State 
office not to file felony criminal charges against Epstein because the 
underage females lacked credibility and thus could not be believed that they were at 
Epstein's house, despite him being an eyewitness that the underage girls were actually 
there; (f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually 
exploited by not only Epstein but also Epstein's "adult male peers, including royalty, 
politicians, academicians, businessmen, and/or other professional and personal 
acquaintances" — categories that Dershowitz and acquaintances of Dershowitz fall into; 
(g) during the years 2002-2005 Alan Dershowitz was on Epstein's plane on several 
occasions according to the flight logs produced by Epstein's pilot and information 
(described above) suggested that sexual assaults may have taken place on the plane; (h) 
Epstein donated Harvard S30 Million dollars one year, and Harvard was one of the only 
institutions that did not return Epstein's donation after he was charged with sex offenses 
against children. Based on this information, I believed that Dershowitz might have 
relevant information to provide in the cases against Jeffrey Epstein and accordingly 
provided notice of a possible deposition. 
IS. Epstein alleges that there was something improper in the fact that I notified him that I 
intended to take Bill 
deposition. Clinton was properly noticed because: (a) it 
was well known that Clinton was friends with Ghiglaine Maxwell, and several witnesses 
had provided information that Maxwell helped to run Epstein's companies, kept images 
of naked underage children on her computer, helped to recruit underage children for 
Epstein, engaged in lesbian sex with underage females that she procured for Epstein, 
and photographed underage females in sexually explicit poses and kept child 
pornography on her computer; (b) newpaper articles stated that Clinton had an affair 
with Ghislaine Maxwell, who was thought to be second in charge of Epstein's child 
molestation ring. The Cleveland Leader newspaper, April 10, 2009; (c) it was national 
news when Clinton traveled with Epstein (and Maxwell) aboard Epstein's private plane 
to Africa and the news articles classified Clinton as Epstein's friend; (d) the flight logs 
for the relevant years 2002 - 2005 showed Clinton traveling on Epstein's plane on more 
than 10 occasions and his assistant, Doug Band, traveled on many more occasions; (e) 
Jane Doe No. 102 stated generally that she was required by Epstein to be sexually 
EFTA00597853

exploited by not only Epstein but also Epstein's "adult male peers, including royalty, 
politicians, academicians, businessmen, and/or other professional and personal 
acquaintances" — categories Clinton and acquaintances of Clinton fall into; (f) 
logs showed that Clinton took many flights with Epstein, Ghistaint Maxwell, 
and Adrian S 
— all employees and/or co-conspirators of Epstein's that 
were closely connected to Epstein's child exploitation and sexual abuse; (g) Clinton 
frequently flew with Epstein aboard his plane, then suddenly stopped — raising the 
suspicion that the friendship abruptly ended, perhaps because of events related to 
Epstein's sexual abuse of children; (h) Epstein's personal phone directory from his 
computer contains e-mail addresses for Clinton along with 21 phone numbers for him, 
Si
i
dfri those for his assistant (Doug Band), his schedulers, and what appear to be 
personal numbers. Based on this information, I believed that Clinton might 
have relevant information to provide in the cases against Jeffrey Epstein and 
accordingly provided notice of a possible deposition. 
16. Epstein alleges that Tommy Mottola was improperly noticed with a deposition. I did 
not notice Mattola for deposition. 
He was noticed for deposition by a law firm 
representing another one of Epstein's victims — not by me. 
17. Epstein alleges that there was something im 
in the fact that I notified him that I 
intended to take the illusionist David 
deposition. 
Coppcdleld was 
properly noticed because: (a) Epstein's housekeeper Alfredo Rodriguez testified that 
David Copperfield was a guest on several occasions at Epstein's house; (b) according to 
the message pads confiscated from Epstein's house, Copperfield called Epstein quite 
frequently and left messages that indicated they socialized together; (c) Copperfield 
himself has had similar allegations made against him by women claiming he sexually 
abused them; (d) one of Epstein's sexual assault victims also alleged that Copperfield 
had touched her in an improper sexual way while she was at Epstein's house. Based on 
this information, I believed that Copperfield might have relevant information to provide 
in the cases against Jeffrey Epstein and accordingly provided notice of a possible 
deposition. 
18. Epstein alleges that there was something improper in the fact that I identified Bill 
Richardson as a possible witness against him in the civil cases. Richardson was 
properly identified as a possible witness because Epstein's personal pilot testified to 
Richardson joining Epstein at Epstein's New Mexico Ranch. See deposition of Larry 
Morrison, October 6, 2009, at 167-169. There was information indicating that Epstein 
had young girls at his ranch which, given the circumstances of the case, raised the 
reasonable inference he was sexually abusing these girls since he had regularly and 
frequently abused girls in West Palm Beach and elsewhere. Richardson had also 
returned campaign donations that were given to him by Epstein, indicating that he 
believed that there was something about Epstein that he did not want to be associated 
with. Richardson was not called to testify nor was he ever subpoenaed to testify. 
19. Epstein alleges that discovery of plane and pilot logs was improper during discovery in 
the civil cases against him. Discovery of these subjects was clearly proper and 
EFTA00597854

/-3 
necessary because: (a) Jane Doe filed a federal RICO claim against Epstein that was an 
active claim through much of the litigation. The RICO claim alleged that Epstein ran an 
expansive criminal enterprise that involved and depended upon his plane travel. 
Although Judge Marra dismissed the RICO claim at some point in the federal litigation, 
the legal team representing my clients intended to pursue an appeal of that dismissal. 
Moreover, all of the subjects mentioned in the RICO claim remained relevant to other 
aspects of Jane 
claims against Epstein, including in particular her claim for 
punitive da
les; (b) Jane Doe also filed and was proceeding to trial on a federal claim 
under 18 
§ 2255. Section 2255 is a federal statute which (unlike other state 
statutes) guaranteed a minimum level of recovery for Jane Doe. Proceeding under the 
statute, however, required a "federal nexus" to the sexual assaults. Jane Doe had two 
grounds on which to argue that such a nexus existed to her abuse by Epstein: first, his 
use of the telephone to arrange for girls to be abused; and, second, his travel on planes 
in interstate commerce. During the course of the litigation, I anticipated that Epstein 
would argue that Jane 
proof of the federal nexus was inadequate. These fears 
were realized when Epstein filed a summary judgment motion raising this argument In 
respo-nse, the other attorneys and I representing Jane Doe used the flight log evidence 
to respond to Epstein's summary judgment motion, explaining that the flight logs 
demonstrated that Epstein had traveled in interstate commerce for the purpose of 
facilitating his sexual assaults. Because Epstein chose to settle the case before trial, 
Judge Marra did not rule on the summary judgment motion. (c) Jane Doe No. 102'1 
complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as 
young as 12 years old and alleged that he used his plane to transport underage females 
to be sexually abused by him and his friends. The flight logs accordingly might have 
information about either additional girls who were victims of Epstein's abuse or friends 
of Epstein who may have witnessed or even participated in the abuse. Based on this 
information, I believed that the flight logs and related information was relevant 
information to prove the cases against Jeffrey Epstein and accordingly I pursued them 
in discovery. 
20. In approximately November 2009, the existence of Scott 
Ponzi scheme 
became public knowledge. It was at that time that I, along with many other reputable 
attorneys at RRA, first became aware of Rothstein criminal scheme. At that time, I left 
RRA with several other RRA attorneys to form the law firm of Farmer Jaffe Weissing 
Edwards Fistos and Lehrman ("Fanner Jaffe"). I was thus with RRA for less than one 
year. 
21. In July 2010, along with other attorneys at Farmer Jaffe and Professor Cassell, I reached 
favorable settlement terms for my three clients L.M., E.W., and Jane Doe in their 
lawsuits against Epstein. 
22. On July 20, 2010, I received a letter from the 
Office for the Southern 
District of Florida — the office responsible for prosecuting 
Ponzi scheme. 
The letter indicated that law enforcement agencies had determined that I was "a victim 
(or potential victim)" of Scott 
federal crimes. The letter informed me of my 
rights as a victim of 
federal crimes and promised to keep me informed about 
EFTA00597855

es) 
0 
subsequent developments in his prosecution. A copy of this letter is attached to this 
Affidavit. (A copy of the letter is attached to Statement of Undisputed Facts as Exhibit 
UU) 
23. Jeffiey Epstein also filed a complaint with the Florida Bar against me. His complaint 
alleged that I had been involved in 
scheme and had thereby violated various 
rules of professional responsibility. The Florida Bar investigated and dismissed the 
complaint. 
24. I have reviewed the Statement of Undisputed Facts filed contemporaneously with this 
Affidavit. Each of the assertions concerning what I learned, what I did, and the good 
faith beliefs formed by me in the course of my prosecutions of claims against Jeffrey 
Epstein as contained in the Statement of Undisputed Facts is true, and the foundations 
set out as support for my beliefs are true and correct to the best of my knowledge. 
25. All actions taken by me in the course of my prosecution of claims against Jeffrey 
Epstein were based upon a good faith belief that they were reasonable, necessary, and 
ethically proper to fulfill my obligation to zealously represent the interests of my 
clients. 
I declare under penalty of perjury that the foregoing is true and correct. 
Dated: /21 
 
, 2010 
EFTA00597856

IN THE CIRCUIT COURT OF THE 15TH 
JUDICIAL CIRCUIT IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
Case No.: 50 2009CA 040800)COCCKBAG 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually, and 
BRADLEY J. EDWARDS, individually, 
Defendants, 
DEFENDANT BRADLEY J. 
RENEWED MOTION FOR FINAL SUMMARY JUDGMENT 
Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and 
pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby moves for Final Summary 
Judgment and in support thereof states as follows: 
I. INTRODUCTION 
The pleadings and discovery taken to date show that 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 Epstein's Second Amended 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 of Edwards' 
involvement in the prosecution of legitimate claims against Epstein. Epstein sexually abused 
three clients of Edwards — L.M., E.W., and Jane Doe — and Edwards properly and successfully 
EXHIBIT 
I g 
EFTA00597857

represented them in a civil action against Epstein. Nothing in 
capable and competent 
representation of his clients can serve as the basis for a civil lawsuit against him. Allegations 
about 
participation in or knowledge of the use of the civil actions against Epstein in a 
"Ponzi Scheme" are not supported by any competent evidence and could never be supported by 
competent evidence as they are entirely false. 
A. 
Epstein's Complaint 
Epstein's Second Amended Complaint essentially alleges that Epstein was damaged by 
Edwards, acting in concert with Scott Rothstein (President of the Rothstein Rosenfeldt Adler law 
fum ("RRA") where Edwards worked for a short period of time). Epstein appears to allege that 
Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to 
"pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were 
told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and 
Jane Doe were to be paid up-front money to prevent those girls from settling their civil cases 
against Epstein. In Epstein's view, these child sexual assault cases had "minimal value" 
(Complaint & 42(h)), and 
refusal to force his clients to accept modest settlement 
offers is claimed to breach some duty that Edwards owed to Epstein. Interestingly, Epstein never 
states that he actually made any settlement offers. 
The supposed "proof' of the 
allegations against Edwards includes 
alleged contacts with the media, his attempts to obtain discovery from high-profile 
persons with whom Epstein socialized, and use of "ridiculously inflammatory" language in 
arguments in court. Remarkably, Epstein has filed such allegations against Edwards despite the 
fact that Epstein had sexually abused each of 
clients and others while they were 
2 
EFTA00597858

minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than 
answer questions about the extent of the sexual abuse of his many victims. Even more 
remarkably, since filing his suit against Edwards, Epstein has now settled the three cases 
Edwards handled for an amount that Epstein insisted be kept confidential. Without violating the 
strict confidentiality terms required by Epstein, the cases did not settle for the "minimal value" 
that Epstein suggested in his Complaint. Because Epstein relies upon the alleged discrepancy 
between the "minimal value" Epstein ascribed to the claims and the substantial value Edwards 
sought to recover for his clients, the settlement amounts Epstein voluntarily agreed to pay while 
these claims against Edwards were pending will be disclosed to the court in-camera. 
B. Summary of the Argument 
Bradley J. Edwards, Esq., is entitled to summary judgment on Epstein's frivolous claim 
for at least three separate reasons. 
First, because Epstein has elected to hide behind the shield of his right against self 
incrimination to preclude his disclosing any relevant information about the criminal activity at 
the center of his claims, he is barred from prosecuting this case against Edwards. Under the 
well-established "sword and shield" doctrine, Epstein cannot seek damages from Edwards while 
at the same time asserting a Fifth Amendment privilege to block relevant discovery. His case 
must therefore be dismissed. 
Second, all of Edwards' conduct in the prosecution of valid claims against Epstein is 
protected by the litigation privilege. 
Third, and most fundamentally, Epstein's lawsuit should be dismissed because it is not 
only unsupported by but is also directly contradicted by all of the record evidence. From the 
3 
EFTA00597859

beginning, Edwards diligently represented three victims of sexual assaults perpetrated by 
Epstein. As explained in detail below, each and every one of 
litigation decisions was 
grounded in proper litigation judgment about the need to pursue effective discovery against 
Epstein, particularly in the face of Epstein's stonewalling tactics. 
successful 
representation fmally forced Epstein to settle and pay appropriate damages. Effective and proper 
representation of child victims who have been repeatedly sexually assaulted cannot form the 
basis of a separate, !'satellite" lawsuit, and therefore Edwards is entitled to summary judgment on 
these grounds as well. 
The truth is the record is entirely devoid of any evidence to support Epstein's claims and 
is completely and consistently corroborative of 
sworn assertion of innocence. Put 
simply, Epstein has.made allegations that have no basis in fact. To the contrary, his lawsuit was 
merely a desperate measure by a serial pedophile to prevent being held accountable for 
repeatedly sexually abusing minor females. Epstein's ulterior motives in filing and prosecuting 
this lawsuit are blatantly obvious. Epstein's behavior is another clear demonstration that he feels 
he lives above the law and that because of his wealth he can manipulate the system and pay for 
lawyers to do his dirty work - even to the extent of having them assert baseless claims against 
other members of the Florida Bar. Epstein's Second Amended Complaint against Edwards is 
nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to 
support his preposterous claims. It was his last ditch effort to escape the public disclosure by 
Edwards and his clients of the nature, extent, and sordid details of his life as a serial child 
molester. 
Motion for Summary Judgment should be granted without equivocation. 
4 
EFTA00597860

ARGUMENT 
H. 
EDWARDS IS ENTITLED TO SUMMARY JUDGMENT ON EPSTEIN'S 
CLAIM BECAUSE THERE ARE NO MATERIAL DISPUTED FACTS AND THE 
UNDISPUTED FACTS ESTABLISH THAT 
CONDUCT COULD 
NOT POSSIBLY FORM THE BASIS OF ANY LIABILITY IN FAVOR OF EPSTEIN 
A. The Summary Judgment Standard. 
Rule 1.510(c), Florida Rules of Civil Procedure, provides that a court may enter summary 
judgment when the pleadings, depositions and factual showings reveal that there is no genuine 
issue of material fact and that the moving party is entitled to judgment as a matter of law. See 
Snyder v. Cheezem Development Corp., 373 So. 2d 719, 720 (Fla. 2d DCA 1979); Rule 1.510(c), 
Fla. R. Civ. P. Once the moving party conclusively establishes that the nonmoving party cannot 
prevail, it is incumbent on the nonmoving party to submit evidence to rebut the motion for 
summary judgment. See Hall v. Talcoti, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the 
opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 
764 (Fla.1996); Landers v. Milton, 370 So.2d 368, 370 (Fla.1979) (same). 
Moreover, it is well-recognized that the non-moving party faced with a summary 
judgment motion supported by appropriate proof may not rely on bare, conclusory assertions 
found in the pleadings to create an issue and thus avoid summary judgment. Instead, the party 
must produce counter-evidence establishing a genuine issue of material fact. See Bryant v. 
Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985); 
see also Lanzner v. City of North Miami Beach, 141 So.2d 626 (Fla. 3d Dist Ct. App. 1962) 
(recognizing that mere contrary allegations of complaint were not sufficient to preclude summary 
judgment on basis of facts established without dispute). Where the nonmoving party fails to 
5 
EFTA00597861

present evidence rebutting the motion for summary judgment and there is no genuine issue of 
material fact, then entry of judgment is proper as a matter of law. See Davis v. Hathaway, 408 
So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. 
B. Epstein's Claim Regarding Edwards Have Absolutely No Factual Basis. 
This is not a complicated case for granting summary judgment. To the contrary, this is a 
simple case for summary judgment because each and every one of Epstein's claim against 
Edwards lacks any merit whatsoever.' 
1. 
Epstein's allegations regarding Edwards' involvement in 
"Ponzi 
Scheme" are unsupported and unsupportable because he was simply not 
involved in any such scheme. 
a. Edwards Had No Involvement in the Ponzi Scheme. 
The bulk of Epstein's claims against Edwards hinge on the premise that Edwards was 
involved in a Ponzi scheme run by Scott Rothstein. Broad allegations of wrongdoing on the part 
of Edwards are scattered willy-nilly throughout the complaint. None of the allegations provide 
any substance as to how Edwards actually assisted the Ponzi scheme, and allegations that he 
"knew or should have known" of its existence are based upon an impermissible pyramiding of 
inferences. In any event, these allegations all fail for one straightforward reason: Edwards was 
simply not involved in any Ponzi scheme. He has provided sworn testimony and an affidavit in 
support of that assertion, and there is not (and could never be) any contrary evidence. 
Edwards has now been deposed at length in this case. As his deposition makes crystal 
clear, he had no knowledge of any fraudulent activity in which Scott Rothstein may have been 
A decision by the Court to grant summary judgment on Epstein's claims against Edwards would not affect 
Epstein's claims against Scott Rothstein. Epstein has already chosen to dismiss all of his claims against L.M., the 
only other defendant named in the suit. 
6 
EFTA00597862

involved. See, e.g., Edwards Depo. at 301-02 (Q: " . . . [W]ere you aware that Scott Rothstein 
was trying to market Epstein cases . . . ?" A: "No."). 
Edwards has supplemented his deposition answers with an Affidavit that declares in no 
uncertain terms his lack of involvement in any fraud perpetrated by Rothstein. See, e.g., 
Edwards Affidavit attached to Statement of Undisputed Material Facts as Exhibit "N" at ¶8-10, 
¶20, ¶22-23. Indeed, no reasonable juror could find that Edwards was involved in the scheme, as 
Edwards joined RRA. well after Rothstein began his fraud and would have been already deeply in 
debt. In fact, the evidence of Epstein's crimes is now clear, and 
actions in this case 
were entirely in keeping with his obligation to provide the highest possible quality of legal 
representation for his clients to obtain the best result possible. 
In view of this clear evidence rebutting all allegations against him, Epstein must now 
"produce counter-evidence establishing a genuine issue of material fact." See Bryant v. Shands 
Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985). Epstein 
cannot do this. Indeed, when asked at his deposition whether he had any evidence of 
involvement, Epstein declined to answer, purportedly on attorney-client privilege grounds: 
Q. I want to know whether you have any knowledge of evidence that Bradley 
Edwards personally ever participated in devising a plan through which were sold 
purported confidential assignments of a structured payout settlement? . . . 
A. I'd like to answer that question by saying that the newspapers have reported 
that his firm was engaged in fraudulent structured settlements in order to fleece 
unsuspecting Florida investors. With respect to my personal knowledge, I'm 
unfortunately going to, today, but I look forward to at some point being able to 
disclose it, today I'm going to have to assert the attorney/client privilege. 
See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "Epstein Depo.") at 67-68. 
Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi 
scheme by Rothstein. 
7 
EFTA00597863

b. 
Epstein's Allegations of Negligence by Edwards are Unfounded and Not 
Actionable in Any Event. 
In his Second Amended Complaint Epstein recognizes at least the possibility that 
Edwards was not involved in any Rothstein Ponzi scheme. Therefore, seemingly as a fallback, 
Epstein alleges without explanation that Edwards "should have known" about the existence of 
this concealed Ponzi scheme. Among other problems, this fallback negligence position suffers 
the fatal flaw that it does not link at all to the intentional tort of abuse of process alleged in the 
complaint. 
Epstein's negligence claim is also deficient because it simply fails to satisfy the 
requirements for a negligence cause of action: 
"Four elements are necessary to sustain a negligence claim: 1. A duty, or 
obligation, recognized by the law, requiring the [defendant] to conform to a 
certain standard of conduct, for the protection of others against unreasonable 
risks. 2. A failure on the I 
I part to conform to the standard required: a 
breach of the duty . . . . 3. A reasonably close causal connection between he 
conduct and the resulting injury. This is what is commonly known as `legal 
cause,' or `proximate cause,' and which includes the notion of cause in fact. 4. 
Actual loss or damage. 
Curd v. Mosaic Fertilizer, LLC, 
10.2d 
, 2010 WL 2400384 at *9 (Fla. 2010). Epstein 
does not allege a particular duty on the part of Edwards that has been breached. Nor does 
Epstein explain how any breach of the duty might have proximately caused him actual damages. 
Summary judgment is therefore appropriate for these reasons as well. 
Finally, for the sake of completeness, it is worth noting briefly that no reasonable jury 
could find Edwards to have been negligent in failing to anticipate that a managing partner at his 
law firm would be involved in an unprecedented Ponzi scheme. Scott Rothstein deceived not 
8 
EFTA00597864

only Edwards but also more than 60 other reputable lawyers at a major law firm. Cf . Sun 
Sentinel, Fort Lauderdale, Dec. 11, 2009, 2009 WLNR 25074193 at *1 ("Sure, some outlandish 
John Grisham murder plot.] sound far-fetched. But if you asked me a few months ago if Scott 
Rothstein was fabricating federal court orders and forging a 
signature on documents to 
allegedly fleece his friends, as federal prosecutors allege, I would have said that was far-fetched, 
too."). No reasonable lawyer could have expected that a fellow member of the bar would have 
been involved in such a plot. Nobody seemed to know of 
Ponzi scheme, not even his 
best friends, or the people he did business with on a daily basis, or even his wife. Many of the 
attorneys at RRA had been there for years and knew nothing. Edwards was a lawyer at RRA for 
less than 8 months and had very few personal encounters with Rothstein during his time at the 
firm, yet Epstein claims that he should have known of 
intricate Ponzi scheme. No 
doubt for this reason the M. 
Office has now listed Edwards as a "victim" of 
crimes. See Statement of Undisputed Facts filed contemporaneously. 
Epstein's Complaint does not offer any specific reason why a jury would conclude that 
Edwards was negligent, and he chose not to offer any explanation of his claim at his deposition. 
Accordingly, Edwards is entitled to summary judgment to the extent the claim against him is 
somehow dependent upon his negligence in failing to discover 
Ponzi scheme. 
2. 
Edwards is Entitled to Summary Judgment to the Extent the Claim Against 
Him is Dependent on Allegations Regarding "Pumping the Cases" Because 
He Was Properly Pursuing the Interests of His Three Clients Who Had Been 
Sexually Abused by Epstein. 
Epstein alleges that Edwards somehow improperly enhanced the value of the three civil 
cases he had filed against Epstein. Edwards represented three young women — L.M., E.W., and 
Jane Doe — by filing civil suits against Epstein for his sexual abuse of them while they were 
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EFTA00597865

minors. Epstein purports to find a cause of action for this by alleging that Edwards somehow 
was involved in "'pumping' these three cases to investors." 
As just explained, to the extent that Epstein is alleging that Edwards somehow did 
something related to the Ponzi scheme, those allegations fail for the simple reason that Edwards 
was not involved in any such scheme. Edwards, for example, could not have possibly "pumped" 
the cases to investors when he never participated in any communication with investors. 
Epstein's "pumping" claims, however, fail for an even more basic reason: Edwards was 
entitled — indeed ethically obligated as an attorney — to secure the maximum recovery for his 
clients during the course of his legal representation. As is well known, "[a]s an advocate, a 
lawyer zealously asserts the 
position under the rules of the adversary system." Fla. Rules 
of Prof. Conduct, Preamble. Edwards therefore was required to pursue (unless otherwise 
instructed by his clients) a maximum recovery against Epstein. Edwards, therefore, cannot be 
liable for doing something that his ethical duties as an attorney required.2
Another reason that Epstein's claims that Edwards was "pumping" cases for investors 
fails is that Edwards filed all three cases almost a year before he was hired by RRA or even knew 
of Scott Rothstein. 
Epstein makes allegations that the complaints contained sensational 
allegations for the purposes of luring investors; however, language in the complaints remained 
virtually unchanged from the first filing in 2008 and from the overwhelming evidence the Court 
can see for itself that all of the facts alleged by Edwards in the complaints were true. 
Epstein ultimately paid to settle all three of the cases Edwards filed against him for more 
money than he paid to settle any of the other claims against him. At Epstein's request, the terms 
2 In a further effort to harass Edwards, Epstein also filed a bar complaint with the Florida Bar against Edwards. The 
Florida Bar has dismissed that complaint. See Statement of Undisputed Facts. 
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EFTA00597866

of the settlement were kept confidential. The sum that he paid to settle all these cases is 
therefore not filed with this pleading and will be provided to the court for in-camera review. 
Epstein chose to make this payment as the result of a federal court ordered mediation process, 
which he himself sought (over the objection of Jane Doe, Edwards' client in federal court) in an 
effort to resolve the case. See 
Motion for Settlement Conference, or in the 
Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 
(E. Fla. June 28, 2010) (Marra, J.) (doe. #168) attached hereto as Exhibit "A". Notably, 
Epstein sought this settlement conference — and ultimately made his payments as a result of that 
conference - in July 2010, more than seven months after he filed this lawsuit against Edwards. 
Accordingly, Epstein could not have been the victim of any scheme to "pump" the cases against 
him, because he never paid to settle the cases until well after Edwards had left RRA and had 
severed all connection with Scott Rothstein (December 2009). 
In addition, if Epstein had thought that there was some improper coercion involved in, for 
example, Jane 
case, his remedy was to raise the matter before Federal District Court Judge 
Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein 
simply chose to settle that case. He is therefore now barred by the doctrine of res judicata from 
somehow re-litigating what happened in (for example) the Jane Doe case. "The doctrine of res 
judicata makes a judgment on the merits conclusive `not only as to every matter which was 
offered and received to sustain or defeat the claim, but as to every other matter which might with 
propriety have been litigated and determined in that action." AMEC Civil, LLC v. State Dept. of 
Transp., 
So.2d _, 2010 WL 1542634 at *2 (Fla. 1' Dist. Ct. App. 2010) (quoting Kimbrell 
v. Paige, 448 So.2d 1009, 1012 (Fla. 1984). Obviously, any question of improper "pumping" of a 
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EFTA00597867

particular case could have been resolved in that yelp) case rather than now re-litigated in satellite 
litigation. 
3. 
Edwards is Entitled to Summary Judgment on the Claim of 
Abuse of Process Because He Acted Properly Within the Boundaries of the 
Law in Pursuit of the Legitimate Interests of his Clients. 
Epstein's Second Amended Complaint raises several claims of "abuse of process." An 
abuse of process claim requires proof of three elements: "(1) that the defendant made an illegal, 
improper, or perverted use of process; (2) that the defendant had ulterior motives or purposes in 
exercising such illegal, improper, or perverted use of process; and (3) that, as a result of such 
action on the part of the defendant, the plaintiff suffered damage. " I & I Investments v. Payless 
Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4th Dist. Ct. App. 2010) (internal citation omitted). In 
fact, this Court is very familiar with this cause of action, as Edwards has correctly stated this 
cause in his counterclaim against Epstein. Edwards is entitled to summary judgment because 
Epstein cannot prove these elements. 
The first element of an abuse of process claim is that a defendant made "an illegal, 
improper, or perverted use of process." On the surface, Epstein's Complaint appears to contain 
several allegations of such improper process. 
On examination, however, each of these 
allegations amounts to nothing other than a claim that Epstein was unhappy with some 
discovery proceeding, motion or argument made by Edwards. This is not the stuff of an abuse of 
process claim, particularly where Epstein fails to allege that he was required to do something as 
the result of Edwards' pursuit of the claims against him. See Marty v. Gresh, 501 So.2d 87, 90 
(Fla. 1m Dist. Ct. App. 1987) (affirming summary judgment on an abuse of process claim where 
lawsuit caused appellee to do nothing against her will"). 
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EFTA00597868

In any event, none of the allegations of "improper" process can survive summary 
judgment scrutiny, because every action Edwards took was entirely proper and reasonably 
calculated to lead to the successful prosecution of the pending claims against Epstein as detailed 
in Edwards' Affidavit 
Epstein also fails to meet the second element of an abuse of process claim: that Edwards 
had some sort of ulterior motive. The case law is clear that on an abuse of process claim a 
"plaintiff must prove that the process was used for an immediate purpose other than that for 
which it was designed." S&I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 
4th Dist. Ct. App. 2010) (citing Biondo v. Powers, 805 So.2d 67, 69 (Fla. 4th Dist. Ct. App. 2002). 
As a consequence, "[w]here the process was used to accomplish the result for which it was 
intended, regardless of an incidental or concurrent motive of spite or ulterior purpose, there is no 
abuse of process." Id. (internal quotation omitted). Here, Edwards has fully denied any 
improper motive, See Statement of Undisputed Facts, and Epstein has no evidence of any such 
motivation. Indeed, it is revealing that Epstein chose not to ask even a single question about this 
subject during the deposition of Edwards. In addition, all of the actions that Epstein complains 
about were in fact used for the immediate purpose of furthering the lawsuits filed by L.M., E.W., 
and Jane Doe. In other words, these actions all were both intended to accomplish and, in fact, 
successfully "accomplished the results for which they were intended" -- whether it was securing 
additional discovery or presenting a legal issue to the court handling the case or ultimately 
maximizing the recovery of damages from Epstein on behalf of his victims. Accordingly, 
Edwards is entitled to summary judgment on any claim that he abused process for this reason as 
well. 
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EFTA00597869

4. 
Edwards is Entitled to Summary Judgment to the Extent His Claim is Based 
On Pursuit of Discovery Concerning Epstein's Friends Because All Such 
Efforts Were Reasonably Calculated to Lead to Relevant and Admissible 
Testimony About Epstein's Abuse of Minor Girls. 
Epstein has also alleged that Edwards improperly pursued discovery from some his close 
friends. 
Such discovery, Epstein claims, was improper because Edwards knew that these 
individuals lacked any discoverable information about the sexual assault cases against Epstein. 
Here again, Edwards is entitled to summary judgment, as each of the friends of Epstein 
were reasonably believed to possess discoverable information. The undisputed facts show the 
following with regard to each of the persons raised in Epstein's complaint: 
• With regard to Donald Trump, Edwards had sound legal basis for believing Mr. 
Trump had relevant and discoverable information. See Statement of Undisputed 
Facts. 
• 
With regard to Alan Dershowitz (Harvard Law Professor), Edwards had sound 
legal basis for believing Mr. Dershowitz had relevant and discoverable 
information. See Statement of Undisputed Facts. 
• 
With regard to former President Bill Clinton, Edwards had sound legal basis for 
believing former President Clinton had relevant and discoverable information. 
See Statement of Undisputed Facts. 
• 
With regard to former Sony Record executive Tommy Mottola, Edwards was not 
the attorney that noticed Mr. 
deposition. See Statement of Undisputed 
Facts. 
• With regard to illusionist David Copperfield, Edwards had sound legal basis for 
believing Mr. Copperfield had relevant and discoverable information. 
See 
Statement of Undisputed Facts. 
• With regard to former New Mexico Governor Bill Richardson, Edwards had 
sound legal basis for naming Former New Mexico Governor Bill Richardson on 
his witness list. See Statement of Undisputed Facts. 
It is worth noting that the standard for discovery is a very liberal one. To notice someone 
for a deposition, of course, it is not required that the person deposed actually end up producing 
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EFTA00597870