018.pdf

NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG ,._,, ~ (:) \.D .:....,:-~ c::, Ii(. rr1 ...._ C'"') ,- N ~ -.,,......-;r:;i . Defendants, . C a ~ .--;~-•- t=- ::J: --.::,. I ,,._J .-.r....:c-: r- --------------- .. 0 ANSWER AND COUNTERCLAIM OF DEFENDANT, BRADLEY J. EDWARD~ Defendant, BRADLEY J. EDWARDS, individually, by and through his undersigned attorneys files his Answer and Counterclaim to the Complaint filed by Plaintiff, JEFFREY EPSTEIN, in the above-styled matter on December 7, 2009 as follows: ANSWER GENERAL ALLEGATIONS 1. Defendant, EDWARDS, denies the allegations contained in Paragraph 1 and demands strict proof thereof. 2. Defendant, EDWARDS, admits the allegations contained in Paragraph 2. 3. Defendant, EDWARDS, admits the allegations contained in Paragraph 3. 4. Defendant, EDWARDS, admits the allegations contained in Paragraph 4. • ·-· NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Edwards Page 2 of 16 5. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 5 and thereby denies these allegations and demands strict proof thereof. 6. Defendant, EDWARDS, admits that he is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida, otherwise Defendant, EDWARDS, denies the balance of the allegations contained in Paragraph 6 and demands strict proof thereof. 7. Defendant, EDWARDS, admits that Defendant, L.M. is an individual residing in Palm Beach County, Florida represented by RRA and EDWARDS in a civil lawsuit against Epstein, and is now represented by EDWARDS but no longer represented by RRA. Otherwise Defendant, EDWARDS, denies the balance of the allegations contained in Paragraph 7 including but not limited to the allegation that L.M. was ever represented by ROTHSTEIN and demands strict proof thereof. 8. Defendant, EDWARDS, admits 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 business and filed lawsuits on behalf of clients in Palm Beach County, Florida; however, RRA never filed a lawsuit on behalf of L.M., nor did it file lawsuits on behalf of other victims against EPSTEIN. Those lawsuits were filed by EDWARDS prior to any association with or knowledge of RRA. Otherwise Defendant, EDWARDS, denies the balance of the allegations contained in Paragraph 8 and demands strict proof thereof. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Edwards Page 3 of 16 9. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 9 and thereby denies these allegations and demands strict proof thereof. 10. Defendant, EDWARDS, admits that RRA held itself out as legitimately and properly engaging in the practice of law, otherwise Defendant, EDWARDS is without knowledge to either admit or deny the balance of the allegations contained in Paragraph 10 and thereby denies these allegations and demands strict proof thereof. 11. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 11 and thereby denies these allegations and demands strict proof thereof. 12. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 12 and thereby denies these allegations and demands strict proof thereof. 13. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 13 and thereby denies these allegations and demands strict proof thereof. 14. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 14 and thereby denies these allegations and demands strict proof thereof. 15. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 15 and thereby 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 without knowledge to either admit or deny the allegations contained in Paragraph 16 and thereby denies these allegations and demands strict proof thereof. 17. Defendant, EDWARDS, admits the allegations contained in Paragraph 17. 18. Defendant, EDWARDS, denies the allegations contained in Paragraph 18 and demands strict proof thereof. 19. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 19 and thereby denies these allegations and demands strict proof thereof. 20. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 20 and thereby denies these allegations and demands strict proof thereof. 21. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 21 and thereby denies these allegations and demands strict proof thereof. 22. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 22 and thereby denies these allegations and demands strict proof thereof. 23. Defendant, EDWARDS, admits that the identity of claimants against Epstein was shielded through the use of initials. All other allegations of Paragraph 23 are denied and Defendant demands strict proof thereof. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Edwards Page 5 of 16 24. Defendant, EDWARDS, admits that he represented claimants against Epstein on behalf of RRA. All other allegations of Paragraph 24 are denied and Defendant demands strict proof thereof. 25. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 25 and thereby denies these allegations and demands strict proof thereof. 26. Defendant, EDWARDS, denies 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 without knowledge to either admit or deny the allegations contained in Paragraph 28 except that EDWARDS admits the evidence against Epstein was, in fact, real. 29. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 29 and thereby denies these allegations and demands strict proof thereof. 30. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 30 and thereby denies these allegations and demands strict proof thereof. 31. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in Paragraph 31 except that EDWARDS specifically denies that he engaged in or had knowledge of any of the alleged unethical or illegal conduct. NOT A CERTIFIED COPY Epstein v. Rothstein: Answer and Counterclaim of Edwards Page 6 of 16 32. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations conta