522.pdf

NOT A CERTIFIED COPY #291874/mep JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). I ---------------- IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA DEFENDANT/COUNTERPLAINTIFF, EDWARDS' RENEWED MOTION FOR LEA VE TO ASSERT CLAIM FOR PUNITIVE DAMAGES Counter-plaintiff, BRADLEY J. EDWARDS, moves this Honorable Court for entry of an Order granting him leave to assert a claim for punitive damages against the Counter-defendant, JEFFREY EPSTEIN, and in support thereof would show that the record evidence presented to the Court in support of Edwards' Motion for Summary Judgment satisfies the statutory prerequisites for the assertion of a punitive damage claim. Specifically, the evidence establishes that EPSTEIN's Complaint against EDWARDS; 1. was filed in the total absence of evidence to support any allegation of wrongdoing on the part of EDWARDS; 2. was filed in the total absence of evidence that EPSTEIN had sustained damage as a consequence of any misconduct other than his own well-established criminal enterprise; NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Renewed Motion for Leave to Assert Claim for Punitive Damages 3. was filed in the absence of any intention to meet his own obligation to provide relevant-and material discovery; 4. was filed for the sole purpose of attempting to intimidate both EDWARDS and EDWARDS' clients and others into abandoning their legitimate claims against EPSTEIN. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Electronic and U.S. Mail to all Counsel on the attache 1st, th /1~ay of August, 2012. o.: 169440 S ar Denney Scarola Barnhart & Shipley 9 Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for BRADLEY J. EDWARDS 2 NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Edwards' Renewed Motion for Leave to Assert Claim for Punitive Damages COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire brad@pathtojustice.com Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 3 Marc S. Nurik, Esquire marc@nuriklaw.com Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Tonja Haddad Coleman, Esquire tonj a@tonjahaddadpa.com Law Offices of Tonja Haddad, P.A. 524 S Andrews A venue, Suite 200N Fort Lauderdale, FL 33301 Phone: (954)-467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein Lilly Ann Sanchez, Esquire lsanchez@thelsfirm.com The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: (305)-503-5503 Fax: (305)-503-6801 Attorneys for Jeffrey Epstein