Epstein Secrets

uestion of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). Grounds for Reconsideration The detailed and documented facts from Epstein's affidavit quoted below, along with the un

s complaint. WHEREFORE, Epstein respectfully seeks reconsideration and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA00808220 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Gol

question of law to be determined by the court under the facts and circumstances of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The well-documented and undisputed facts in existence at the time Epstein file

ration of this Court's oral ruling on the issue of probable cause, and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Gol

be determined by the court under the facts and circumstances 16 EFTA00583967 of each case.'" Id. (citations omitted) (citing City of Pensacola v. Owens, 369 So.2d 328 (Fla.1979)). UNDISPUTED GROUNDS FOR SUMMARY JUDGMENT The reasonable suspicion that gives rise to probable cause for Epstein's suit

opportunity for the parties to be heard at oral argument regarding any assertions by Edwards attempting to refute the existence of probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atte