019.pdf

NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff, vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG • ~ 1,1•,>; i:! ... :) ••• I ·-i;·,·; SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, 0 0 ·' .• ·7') Defendants, I ---------------- ANSWER AND COUNTERCLAIM :F DEFENDANT, BRADLEY J. EDWARDS Defendant, BRADLEY J. EDWAR.:JS, individually, by and through his undersigned attorneys files his Answer and Countercl2.:::n to the Complaint filed by Plaintiff, JEFFREY EPSTEIN, in the above-styled matter on De"ember 7, 2009 as follows: icNSWER GENERA:_, ALLEGATIONS I. Defendant, EDWARDS, den:~s the allegations contained in Paragraph 1 and demands strict proof thereof. 2. Defendant, EDWARDS, ad:rr._=.'~s the allegations contained in Paragraph 2. 3. Defendant, EDWARDS, ad:rr._:~'~s the allegations contained in Paragraph 3. 4. Defendant, EDWARDS, adrr;:~s the allegations contained in Paragraph 4. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of EQwards Page 2 of 16 5. Defendant, EDWARDS, is w:·~hout knowledge to either admit or deny the allegations contained in Paragraph 5 and the::eby denies these allegations and demands strict proof thereof 6. Defendant, EDWARDS, adr:.:ts that he is an individual residing in Broward County, Florida and is licensed to practice lc:w in the State of Florida, otherwise Defendant, EDWARDS, denies the balance of the alleglljons contained in Paragraph 6 and demands strict proof thereof. 7. Defendant, EDWARDS, adr::.its that Defendant, L.M. is an individual residing in Palm Beach County, Florida represented by~ and EDWARDS in a civil lawsuit against Epstein, and is now represented by EDWA?:.:JS but no longer represented by RRA. Otherwise Defendant, EDWARDS, denies the balance ~fthe allegations contained in Paragraph 7 including but not limited to the allegation that L.M. w2..s ever represented by ROTHSTEIN and demands strict proof thereof 8. Defendant, EDWARDS, adr:.Js that non-party RRA was a Florida Professional Service Corporation, with a principal address of 401 East Las Olas Boulevard, Suite 1650, Ft. Lauderdale, FL 33401, and it conducted bus::1ess and filed lawsuits on behalf of clients in Palm Beach County, Florida; however, RRA new::: filed a lawsuit on behalf of L.M., nor did it file lawsuits on behalf of other victims against 3?STEIN. Those lawsuits were filed by EDWARDS prior to any association with or knowledge ~[RRA. Otherwise Defendant, EDWARDS, denies the balance of the allegations contained in Fa.ragraph 8 and demands strict proof thereof. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Ee wards Page 3 of 16 9. Defendant, EDWARDS, is w::·::1out knowledge to either admit or deny the allegations contained in Paragraph 9 and the::eby denies these allegations and demands strict proof thereof. 10. Defendant, EDWARDS, adrr_:':s that RRA held itself out as legitimately and properly engaging in the practice of law, otl:5::-wise Defendant, EDWARDS is without knowledge to either admit or deny the balan~e of the allegations contained in Paragraph 10 and thereby denies these allegations and demanc.s strict proof thereof. 11. Defendant, EDWARDS, is w.faout knowledge to either admit or deny the allegations contained in Paragraph 11 and tl:~reby denies these allegations and demands strict proof thereof. 12. Defendant, EDWARDS, is v/.'~hout knowledge to either admit or deny the allegations contained in Paragraph 12 and ttereby denies these allegations and demands strict proof thereof. 13. Defendant, EDWARDS, is w:·:hout knowledge to either admit or deny the allegations contained in Paragraph 13 and tl:ereby denies these allegations and demands strict proof thereof. 14. Defendant, EDWARDS, is w:·:hout knowledge to either admit or deny the allegations contained in Paragraph 14 and tl:ereby denies these allegations and demands strict proof thereof. 15. Defendant, EDWARDS, is wi':hout knowledge to either admit or deny the allegations contained in Paragraph 15 and t~-::ereby denies these allegations and demands strict proof thereof. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Edwards Page 4 of 16 16. Defendant, EDWARDS, is wi-!hout knowledge to either admit or deny the allegations contained in Paragraph 16 and fr_,_ereby denies these allegations and demands strict proof thereof. 17. Defendant, EDWARDS, adr.:-:.:·~s the allegations contained in Paragraph 17. 18. Defendant, EDWARDS, den'._es the allegations contained in Paragraph 18 and demands strict proof thereof. 19. Defendant, EDWARDS, is wi·~hout knowledge to either admit or deny the allegations contained in Paragraph 19 and ttereby denies these allegations and demands strict proof thereof. 20. Defendant, EDWARDS, is w:~hout knowledge to either admit or deny the allegations contained in Paragraph 20 and tt:ereby denies these allegations and demands strict proof thereof. 21. Defendant, EDWARDS, is W:thout knowledge to either admit or deny the allegations contained in Paragraph 21 and tl:.e::.-eby denies these allegations and demands strict proof thereof. 22. Defendant, EDWARDS, is w:.thout knowledge to either admit or deny the allegations contained in Paragraph 22 and tl:e:eby denies these allegations and demands strict proof thereof. 23. Defendant, EDWARDS, adrr.:Js that the identity of claimants against Epstein was shielded through the use of initials. All othe~-allegations of Paragraph 23 are denied and Defendant demands strict proof thereof. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim ofEc(,.vards Page 5 of 16 24. Defendant, EDWARDS, adrr.~·~s that he represented claimants against Epstein on behalf of RRA. All other allegations of ParE.graph 24 are denied and Defendant demands strict proof thereof. 25. Defendant, EDWARDS, is ~i.'~hout knowledge to either admit or deny the allegations contained in Paragraph 25 and ttereby denies these allegations and demands strict proof thereof. 26. Defendant, EDWARDS, den:es the allegations contained in Paragraph 26 and demands strict proof thereof. 27. Defendant, EDWARDS, denies the allegations contained in Paragraph 27 and demands strict proof thereof. 28. Defendant, EDWARDS, is w~'~hout knowledge to either admit or deny the allegations contained in Paragraph 28 excep'.: -~hat EDWARDS admits the evidence against Epstein was, in fact, real. 29. Defendant, EDWARDS, is wi'J1out knowledge to either admit or deny the allegations contained in Paragraph 29 and tb::eby denies these allegations and demands strict proof thereof. 30. Defendant, EDWARDS, is w:~1out knowledge to either admit or deny the allegations contained in Paragraph 30 and the:·eby denies these allegations and demands strict proof thereof. 31. Defendant, EDWARDS, is w:·~.1out knowledge to either admit or deny the allegations contained in Paragraph 31 except :hat EDWARDS specifically denies that he engaged in or had knowledge of any of the a:~_eged unethical or illegal conduct. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Eciwards Page 6 of 16 32. Defendant, EDWARDS, is w:'.'~hout knowledge to either admit or deny the allegations contained in Paragraph 32 excep-·: -~hat EDWARDS specifically denies that he engaged in or had knowledge of any of the z.~: eged unethical or illegal conduct. 33. Defendant, EDWARDS, is w::_,~hout knowledge to either admit or deny the allegations contained in Paragraph 33 excep··: -~hat EDWARDS spe