Epstein Secrets

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

ts known by the defendant in the malicious prosecution action at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present

at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present to the court and jury." 446 So. 2d at 1167. Here, both the aff

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

ims are not subject to the litigation www.phippsreporting.com 888 811-3408 001237 EFTA00613534 28 1 privilege. 2 And if you read Wright vs. Yurko, you read 3 Judge Cope's concurring opinion, and you read the 4 panel's footnote in SCI, one should not come up 5 with any other conclusion oth

ion 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 recognizes -- that is the Supreme Court i

t. Lauderdale FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 2 A19 EFTA00798185 Tonja Haddad Coleman Fred Haddad 315 S.E. Seventh Street, Suite 301 Haddad & Navarro, PLLC Ft. Lauderdale, FL 33301 1 Financial Plaza, Suite 2612 Fort Lauderdale FL

n determine whether Plaintiff "had a reasonable belief, based on facts and circumstances known to him, in the validity of his claim." See Wright v. Yurko, 446 So. 2d 1162, 1166 (Fla. 5th DCA 1984) (defining probable cause) (citing Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956)). Bifurcating the tria

a state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 So. 2d 702, n.4 (Fla. 3d DCA 2002) (“As the Levin court cited Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues to exist and would not

: (954)-745-5849 Attorneys for Jeffrey Epstein Fax: (954)-745-3556 Attorneys for Scott Rothstein Jack A. Goldberger, Esquire [email protected]; Tonja Haddad Coleman, Esquire [email protected] [email protected]; Atterbury, Goldberger & Weiss, P.A. [email protected]; 250 Australian Avenue South, Suite 140

Atterbury, Goldberger & Weiss, P.A. [email protected]; 250 Australian Avenue South, Suite 1400 [email protected] West Palm Beach, FL 33401 Tonja Haddad, P.A. Phone: (561)-659-8300 315 SE 7th Street, Suite 301 Fax: (561)-835-869 1 Fort Lauderdale, FL 33301 Attomeys for Jeffrey Epstein Phone: (954)-467