Epstein Secrets

r she will not receive a fair trial, and is timely made, it should be granted." Borjas v. Brescher, 579 So. 2d 399, 400 (Fla. 4th DCA 1991) (citing Fischer v. Knuck, 497 So. 2d 240, 242 (Fla.1986)). A trial court, when presented with a motion to disqualify, must limit its review of the motion to a "bare

and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Counsel for Epstein EFTA00589665 SERVI

foregoing was served, via electronic service, to all parties listed below, and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223

via electronic service, to all parties listed below, and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimil

s prosecution action and certifying to the Supreme Court of Florida conflict with Wolfe. In Edwards' appeal, the Fourth District reversed based upon Fischer, and again certified conflict. Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015). Epstein filed for review in the Supreme Court. The Supreme C

Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 17 EFTA00808221

Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 17 EFTA00808221

llenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court issued its decision in Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), declining to follow Wolfe and EFTA00612483 certifying conflict with Wolfe regarding applicatio

e because the contested acts "occurred during and arose out of and were related to and connected with a pending civil action." However, pursuant to Fischer, the litigation privilege does not apply in such cases unless an element of malicious prosecution is lacking. Accordingly, considering this first f

hilip M. Burlington Burlington & Rockenbach, P.A. Imo Tonja Haddad Coleman -18- EFTA00612500 W. Chester Brewer, Jr. W. Chester Brewer. Jr P.A. Tonja Haddad Coleman, P.A. Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards, Fred Haddad Fred Haddad, P.A. Mark Nurik Law Offices of Mark S. Nurik Jack Goldberg

. (A copy of Epstein's Answer Brief is attached as Exhibit B). While the appeal was pending at the Fourth District, that court issued an opinion in Fischer v. Debrincat, 169 So.3d 1204 (Fla. 4th DCA 2015), approved, 217 So.3d 68 (Fla. 2017). In Fischer, the court held that the litigation privilege could

e Fourth District, that court issued an opinion in Fischer v. Debrincat, 169 So.3d 1204 (Fla. 4th DCA 2015), approved, 217 So.3d 68 (Fla. 2017). In Fischer, the court held that the litigation privilege could not be applied to bar a claim for malicious prosecution or abuse of process. The court certified

r Scott Rothstein Jack Goldberger, Esq. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave., Ste. 1400 O1 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. 5315 SE 7th Street., Ste. 301 Fort Lauderdale, FL 33301 ttorneys or e rey pstein Bradley J. Edwards, Esq. FARMER, JAFF

Matter. On or about March 22, 2016, this Court denied Epstein's Motion, without prejudice, stating that if there was "movement" on the Debrincat v. Fischer matter, then it would entertain this Motion. Since the March 22, hearing date, the Debrincat case has been fully briefed and Oral Argument has been

HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this May 2016. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (f

n set before the Florida Supreme Court on the Debrincat case for August 31, 2016. A true and correct copy of the Order granting and setting Oral 2 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00584797 Argument is attached hereto as "Exhibit A." Accordingly, as demons

n May 3, 2017, this Court issued an order directing the petitioner to show cause on or before May 18, 2017 why this Court's decision in Debrincat v. Fischer, 42 Fla. L. Weekly S141 (Fla. Feb. 9, 2017), is not controlling in this case and why the Court should not decline to exercise jurisdiction in this

Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: Fax: Attorneys for Jeffrey Epstein Toda Haddad Coleman, Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phon Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Es uire One E Broward Blvd

prosecution action and certifying to the Supreme Court of Florida conflict with Wolfe. In Edwards' appeal, the Fourth District reversed based upon Fischer, and again certified conflict. Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015). Epstein filed for review in the Supreme Court. The Supreme Co

t Lauderdale, Florida 33301 Fred Haddad, Es 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Toria Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 26 EFTA00799364

prosecution action and certifying to the Supreme Court of Florida conflict with Wolfe. In Edwards' appeal, the Fourth District reversed based upon Fischer, and again certified conflict. Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015). Epstein filed for review in the Supreme Court. The Supreme Co

Lauderdale, Florida 33301 Fred Haddad, Es . 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Toria Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 30 EFTA00583981