Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay away and that the vast majority of discovery and motion practice has already been conducted over the last eight years a stay is not what Epstein is seeking What Epstein really wants is a continuance of the upcoming jury trial on the merits For the reasons stated below however no such continuance is warranted and the Court should deny Epsteins incorrectly-titled and ill-fated motion Procedural History A In Epstein Voluntarily Initiated this Lawsuit Despite Full Knowledge of the prior-filed Doe United States Victims Rights Act Case On July Doe United States case no a Crime Victims Rights Act case was filed on behalf of Jane Doe who was sexually assaulted by Jeffrey Epstein when she was a minor child Four days later Jane Doe filed her Reply to the Governments response to the Doe petition confoming her belief that Epsteins non-prosecution agreement NPA should be declared illegal and that the Federal Court should direct the Government to proceed to negotiate a new agreement in a process that respects Petitioners and the other victims rights On December after being aware for seventeen months that the purpose of the Doe case was to invalidate his Non-Prosecution Agreement Epstein nonetheless voluntarily initiated this civil proceeding alleging that Mr Edwards had fabricated certain civil claims arising from Epsteins systematic sexual abuse of minor female children as part of a fraudulent Ponzi See Epsteins Motion for Temporary Stay at citing to the July Reply Mr Edwards respectfully requests that the Court take judicial notice of the Doe docket pursuant to Fla Stat Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay scheme that Mr Edwards was allegedly running with Scott Rothstein and one of Edwards clients L.M In his initial complaint Epstein emphatically stated that this lawsuit is filed and will be vigorously pursued against all these defendants See Epsteins Initial Complaint at Summary Emphasis added In accordance with this representation to the Court Epstein made no attempt to stay his newly-filed civil case pending the resolution of the Doe Victims Rights Act proceeding On April Epstein filed his Amended Complaint against Mr Edwards in which he expressly addressed the ongoing Doe proceeding Specifically Epstein alleged in paragraph of his Amended Complaint Instead the purpose of requesting those records was to obtain them for use in a separately filed Crime Victims Rights Act CVRA suit Jane Doe and Jane Doe Case No Marra/Johnson which was brought for several purposes including invalidating the Non-Prosecution Agreement Emphasis added Despite now expressly acknowledging to the Court that his NP A could be invalidated Epstein still made no attempt to stay the civil case pending a resolution of Doe On September Epstein moved to intervene on a limited basis in Doe thereby inserting himself into that Victims Rights Act proceeding See Doe United States case no Dkt No One month later on October Mr Edwards filed his Amended Counterclaim in this civil action asserting a claim for malicious prosecution and alleging that Epstein had no basis to initiate this suit in the first place The allegations against Epstein were true and the horrific nature of Epsteins conduct against Mr Edwards clients Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay obviated any need for Mr Edwards to exaggerate his clients claims Once again however Epstein made no attempt to stay this case pending resolution of Doe On August on the eve of a scheduled summary judgment hearing on the validity of Epsteins underlying claims Epstein dismissed his remaining claims against Mr Edwards without having made any attempt to defend against the motion for summary judgment Although the only remaining claim was Mr Edwards counterclaim for malicious prosecution Epstein again made no attempt to stay Mr Edwards counterclaim pending resolution of the Doe matter On December the Court entered its Order on Counter-Plaintiff Edwards Renewed Motion for Leave to Assert Claim for Punitive Damages in which the Court permitted Mr Edwards to amend his counterclaim to seek punitive damages against Epstein By this Order Epsteins personal financial information was now directly at issue in this case Yet Epstein still did not seek a stay pending resolution of the Doe matter For the next five years the paies engaged in vigorous litigation at both the trial and appellate levels concerning Mr Edwards claim for malicious prosecution Substantial discovery was taken At the same time the Doe proceeding continued before the Federal Court as Epsteins victims sought to protect their statutory rights under the Crime Victims Rights Act U.S.C The Doe docket reveals that Epstein continued to be involved in that proceeding and was even a limited paicipant in at least one settlement conference between the paies in See Dkt No permitting Epsteins counsel to be present for the joint opening session after Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay which his counsel may remain in the courthouse on standby and subject to limited participation if deemed appropriate by the Com1 during the course of settlement negotiations Consistent with every action he had taken since voluntarily initiating this civil proceeding way back in Epstein nonetheless never once sought to stay this case pending resolution of the Doe matter In Eight Years Later and on the Eve of Trial Epstein Improperly Seeks a Continuance Based Upon Doe On July this Court entered an Order Specially Setting Jury Trial in which this case was specially set number one for a ten-day jury trial beginning on December Since that Order Epstein has actively availed himself of pre-trial discovery while at the same time making a concerted effort through motion practice to delay Mr Edwards long-awaited day in Com1 This motion practice culminated in the filing of the underlying Motion for Temporary Stay of Proceedings in which Epstein now suggests that the Com1 should indefinitely stay this proceeding pending a resolution of Doe Again however what Epstein really wants is for the Court to indefinitely continue the special set December trial date Epstein claims that despite voluntarily initiating this case in and engaging in protracted litigation and discovery for the last eight years he cannot defend this case at trial and will instead be forced to invoke his Fifth Amendment privileges as a result of the prior-filed Doe proceeding Epsteins motion begs the question of whether he ever intended to pursue the underling claims or whether they were simply an attempt to intimidate Mr Edwards his clients and others into abandoning or settling their legitimate sexual abuse claims for less than their just and reasonable values Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay The Court should deny Epsteins request As demonstrated from the above-described timeline Epstein is barred from seeking any stay/continuance under the doctrines of waiver and equitable estoppel Moreover even if the Court were to consider Epsteins untimely request for a stay/continuance Epstein cannot carry his burden to justify such relief on the eve of trial Epstein initiated this litigation eight years ago He charged that the claims being pursued by Mr Edwards clients were false After eight long years the time has finally come for a jury to determine whether Epstein had any basis for these allegations and Epstein cannot use the prior-filed Doe proceeding to avoid that detennination Memorandum of Law a Epstein Waived Any Argument for a Stay/Continuance Waiver is the intentional or voluntary relinquishment of a known right or conduct which warrants an inference of the relinquishment of a known right Aberdeen Golf Country Club Bliss Const Inc So 2d Fla 4th DCA The elements of waiver are the existence at the time of the waiver of a right privilege advantage or benefit which may be waived the actual or constructive knowledge of the right and the intention to relinquish the right Goodwin Blu Murray Ins Agency Inc So 2d Fla 5th DCA Epstein clearly waived any argument that the Doe United States proceeding justifies a stay or continuance of this case Epstein has been aware since that the Doe proceeding was pending and that one of the potential outcomes was the invalidation of Epsteins Non-Prosecution Agreement Despite these facts Epstein voluntarily filed suit against Mr Edwards on December Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay and then engaged in the following additional affirmative acts to intentionally relinquish any right he may have had to seek a stay or continuance of this proceeding Actively litigating his claims for the next year and a half during which time Epstein had the burden of proof to establish that Mr Edwards had in fact fabricated his clients claims against Epstein Filing his Amended Complaint on April in which Epstein explicitly stated to the Court that one of the potential outcomes of the Doe proceeding was the invalidation of the Non-Prosecution Agreement Failing to move to stay Mr Edwards previously-filed Amended Counterclaim Second Amended Counterclaim or Third Amended Counterclaim all of which included a claim for malicious prosecution Failing to request a stay of these proceedings after moving to intervene in the Doe matter on September Failing to request a stay of these proceedings after voluntarily dismissing his remaining claims against Mr Edwards on August Failing to request a stay of these proceedings after the Court granted Mr Edwards an entitlement to plead for punitive damages thereby putting Epsteins financials at issue on December and Actively defending against Mr Edwards sole-remaining claim for malicious prosecution for the next five years at both the trial and appellate levels thereby causing the parties to incur substantial litigation-related expenses Certainly it is difficult to envision a more clear-cut case of waiver if for no other reason than it was Epstein who initiated this lawsuit in the first place after the Doe proceeding had been pending for well over a year and after he was aware that the purpose of Doe was to invalidate the NPA If Epstein was concerned about the interplay between these two proceedings particularly as it relates to his Fifth Amendment protections he should have immediately moved for a stay after Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Tempora1y Stay he filed suit Epstein failed to do so and instead chose to actively participate in this litigation for nearly a decade Epsteins active participation in litigation that he initiated waives any argument for a stay or continuance C.f Gordon Shield So 3d Fla 4th DCA stating that in the context of arbitration a partys active participation in litigation serves to waive the right to arbitration Epstein is Estopped from Seeking a Stay/Continuance Epsteins attempt to stay/continue this case is also barred by the doctrine of equitable estoppel which has been a fundamental principle of American jurisprudence for centuries Florida Dept of Health Rehab Services S.A.P So 2d Fla Equitable estoppel is based on principals of fair play and essential justice that arises when one party lulls another party into a disadvantageous legal position Bueno Workman So 3d Fla 4th DCA The elements of equitable estoppel are a representation as to a material fact that is contrary to a later-asserted position reliance on that representation and a change in position detrimental to the party claiming estoppel caused by the representation and reliance thereon Id Similar to waiver it is difficult to imagine a more clear-cut example of equitable estoppel than Epsteins eleventh-hour attempt to indefinitely stay litigation that he started based on a situation that he created Epstein filed suit representing to this Court and Mr Edwards that Epstein intended to prove that Mr Edwards had fabricated the sexual abuse allegations against him and stating in no uncertain terms that this lawsuit is filed and will be vigorously pursued n?d w?ۆI2 RcO?I w?B v?v?l 7?MM Go 9k MC M?g6?g EtH W??M B?T??V?v?W v?W j6 nG?1Sr TP X??p Eyy Ϣ??x osiP Cf??t2 i??q NA F?c?O1 M??Щ E?9zV M?ns a rٮ?M gff ȓ?G k??W D?z Dv?m G?DE k_ɻ?mvs??;?j N?h v?R??w F?Aʝl??h?w??g?j 4Cy کVD s?;?da cBxK?A?r m9 Y3 r?y?N F?WW KRd_?mG Pe L??W3sf Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporaty Stay against all these defendants See Epsteins Initial Complaint at Summary Emphasis added Epstein filed his Complaint with full knowledge of the pending Doe United States proceeding and the possibility that his Non-Prosecution Agreement could be invalidated Mr Edwards was forced to defend against these allegations for three years in reliance on Epsteins representations After Epstein voluntarily dismissed his claims Mr Edwards then spent the next five years pursing his malicious prosecution claim which required Epstein to put forth at least some evidence that the allegations asserted in the underlying complaint were true Mr Edwards clients had in fact pursued false sexual abuse claims against Epstein Mr Edwards has therefore expended substantial time and resources in this litigation in reliance on Epsteins representation that Epstein had probable cause to pursue his claims in the first place Now on the eve of trial Epstein has changed tactics and asserted a new position he cannot defend the malicious prosecution claims at the upcoming trial because of the Doe United States proceeding which was filed before Epstein initiated this litigation If that is true how did Epstein intend to prove his claims against Mr Edwards in the first place Ce1iainly if Epstein could not defend against a malicious prosecution claim then he should never have filed the underlying action to begin with Simply put Epsteins eleventh-hour attempt to avoid a trial due to circumstances that he created is unavailing and should be rejected based on the principles of equitable estoppel Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay Epstein Cannot Establish That a Stay/Continuance is atTanted Even if this Court were to consider the merits of Epsteins eleventh-hour request Epstein cannot establish that a stay of the proceedings or continuance of the upcoming trial is warranted As conceded by Epstein there is no constitutional right to a stay of civil proceedings see Epsteins Motion at and this Comi had the discretion to manage its trial docket as it sees fit i A Continuance is Not Warranted Irrespective of the title of his motion what Epstein really wants is for the Court to indefinitely continue the special-set ten-day jury trial scheduled to begin on December Florida law demonstrates that he is entitled to no such relief When evaluating whether a moving party is entitled to a continuance the Court should consider the following factors Whether denial of the continuance creates an injustice for the movant whether the cause of the request for continuance was unforeseeable by the movant and not the result of dilatory practices and whether the opposing party would suffer any prejudice or inconvenience as a result of a continuance Fleming Fleming So 2d Fla 4th DCA At the risk of belaboring the point factor alone prevents Epstein from having the upcoming trial continued Not only was the cause of the request for the continuance foreseeable but Epstein created the situation he now complains of by initiating this civil proceeding with full knowledge that the Doe United States Victims Rights Act case had been pending for at that point well over a year Epstein even cited to Doe in his Amended Complaint in which he confirmed to this Court that the purpose of Doe was to invalidate the NP A Moreover Epstein Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Tempormy Stay certainly engaged in dilatory practices by never once requesting a continuance prior to this eleventh-hour request and instead engaging in protracted litigation at both the trial and appellate levels for nearly eight years Quite simply Epstein cannot stay this case based on a situation he created eight years ago after never once raising the issue until this cause was set for trial Given that Epstein created the situation he now complains of he cannot claim any iajustice if the Court denies his request for a continuance Epstein had eight years to consider the alleged interplay between these proceedings and for eight years Epstein apparently decided that any Fifth Amendment concerns did not justify a stay of his civil proceeding In any event once Epstein filed suit seeking affirmative relief against Mr Edwards he was barred from using the Fifth Amendment as both a shield and sword in these proceedings See Rappapmi Levy So 2d Fla 3d DCA Epstein therefore cannot hide behind the Fifth Amendment to continue this case While he is within his rights to claim the Fifth Amendment privilege before the jury Mr Edwards is equally entitled to argue that an adverse inference may be drawn against Epstein for invoking the right to silence See e.g Atlas Atlas So 2d Fla 4th DCA As to the prejudice to be suffered by the opposing party it is clear that delay is inherently disadvantageous to the party can-ying the burden of proof and here the delays suffered by Mr Edwards have already been extraordinary Fmiher delay related to the CVRA proceedings could add many additional years of prejudice to the detriment suffered by Mr Edwards The CVRA case itself has no predictable end in sight and if the victims claims succeed Epstein faces the potential of years of prosecution of dozens of Federal crimes followed by years more of Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay Federal appeals before his criminal jeopardy is resolved Indeed the issue of whether his exposure to criminal prosecution will ever end is entirely speculative In the meantime the poisonous effects of Epsteins malicious lies about Edwards remain judicially unremedied Edwards is entitled to his day in Court to publicly prove that the scurrilous claims made by Epstein were nothing but a baseless attempt at extortion Justice further delayed is unquestionably justice denied ii A Stay is Not Warranted Florida courts have long-recognized that although under certain circumstances a trial court may grant a stay in a civil proceeding/or a limited time during the pendency of a concurrent criminal proceeding such a stay is not constitutionally required Urquiza Kendall Healthcare Group Ltd So 2d Fla 3d DCA emphasis added For example in Klein Royale Group Ltd the Third District Court of Appeal held that a stay became unreasonable fourteen months after the lawsuit was filed So 2d Fla 3d DCA See also Eller Media Co Serrano So 2d Fla 3d DCA citing Klein Consistent with the Third DCAs decision in Klein Epsteins motion admits that stays are typically limited to the early stages of a related civil proceeding See Epsteins Motion at citing S.E.C Alexander No WL at N.D Cal Dec Specifically Epstein states as follows Expeditious resolution of cases is as a general mater preferable to delay of the Courts docket S.E.C Alexander No WL at N.D Cal Dec However a number of courts have concluded that Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay staying a related civil proceeding in its early stages may prove more efficient in the long run in part because the stay will allow civil discovery to proceed unobstructed by concerns regarding self-incrimination Emphasis Epsteins Here however Epstein is not seeking to stay this civil proceeding in its early stages Rather Epstein is seeking a stay on the eve of trial after voluntarily initiating and actively engaging in this litigation for nearly eight years Such a request is unreasonable under the Alexander case cited by Epstein and as recognized by Urquiza is not constitutionally required under the Fifth Amendment So 2d at Moreover a civil litigants fifth amendment right to avoid self-incrimination may be used as a shield but not a sword Rollins Burdick Hunter ofNew York Inc Euroclassics Ltd Inc So 2d Fla 3d DCA Thus where the party claiming a Fifth Amendment privilege is also seeking affirmative relief that party does not enjoy a carte blanche to invoke the privilege and block its opponents affirmative defenses Rappaport So 2d at holding that order indefinitely continuing trial was premature Here Epstein filed suit against Mr Edwards alleging that Mr Edwards had fabricated certain civil claims arising from Epsteins systematic sexual abuse of minor female children as part of a fraudulent Ponzi scheme that Mr Edwards was allegedly running with Scott Rothstein and one of Mr Edwards clients L.M Epstein has since dismissed his complaint and the only remaining claim is Mr Edwards claim for malicious prosecution which is a mirror image of those brought by Epstein in the first place Epstein cannot seek affirmative relief against Mr Edwards and assume the burden of proof on his claims for years and then tum around on the eve of trial on Mr Edwards counterclaim and suggest Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay to this Court that he cannot even de.fend the validity of the lawsuit that he initiated C.f Rappaport Levy So 2d Fla 3d DCA This was Epsteins lawsuit and the time has come for him to defend its propriety before a jury Conclusion On December Epstein initiated this civil litigation in the face of the ongoing Doe United States Victims Rights Act proceeding In doing so Epstein represented to the Court that this lawsuit is filed and will be vigorously pursued against all these defendants Emphasis added After eight long years the parties are specially set for trial beginning on December and the time has come for Epstein to allow a jury to detem1ine whether the lawsuit that he boldly promised to vigorously pursue had any merit in the first place Defendant/Counter Plaintiff respectfully submits that the Court should deny Epsteins motion and allow this determination to take place Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve b--P to all Counsel on the attached list this _1 __ day of October ITALE JR orney E-Mail jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Edwards Opposition to Epsteins Motion for Temporary Stay COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcbcg aol.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Fanner Jaffe Weissing Edwards Fistos Lehrn1an FL North Andrews A venue Suite Fort Lauderdale FL Phone Nichole Segal Esq njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Courthouse Commons/Suite West Railroad A venue West Palm Beach FL Phone Attorneys for Bradley Edwards Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com fred fredhaddadlaw.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com efiling 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