Epstein Secrets

. vs. Henry, 839 So2d. 702 at Note 4, 18 Third DCA opinion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 recogn

OURT: Off the record for one second. 21 MR. KING: Yes. 22 (Discussion off the record.) 23 MR. RING: And I cited the Taylor case, 24 which was a Supreme Court of Idaho decision, which 25 discusses that issue and which shows that for www.phippsreporting.com 888 811-3408 EFTA00606540 32 1 those very

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The 17 standard is: Did the action have some relation

. vs. Henry, 839 So2d. 702 at Note 4, 18 Third DCA opinion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 24 25

OURT: Off the record for one second. 21 MR. KING: Yes. 22 (Discussion off the record.) 23 MR. KING: And I cited the Taylor case, 24 which was a Supreme Court of Idaho decision, which 25 discusses that issue and which shows that for www.phippereporting.com 888 811-3408 001241 EFTA00613538 32 1 tho

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The :7 standard is: Did the action have some relation

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

law presented in the case at hand, and conducts a detailed analysis of the seminal Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

the central issue of Epstein's liability in the case at hand. Consequently, it would be a waste of judicial resources to proceed to trial prior to the Supreme Court's resolution of this issue. CONCLUSION For all of the reasons above, and in reliance upon the case law cited above, Epstein respectfully requests th

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

al to this Court and is set for Oral Argument on April 28, 2015. 10 EFTA00714933 Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

the central issue of Epstein's liability in the case at hand. Consequently, it would be a waste of judicial resources to proceed to trial prior to the Supreme Court's resolution of this issue. CONCLUSION For all of the reasons above, and in reliance upon the case law cited above, Epstein respectfully requests th

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding