Epstein Secrets

ct that throughout his defense of this action, Epstein maintained that he had no liability to Edwards and that Edwards's actions were barred by, 3 Tonja liaddad, PA. • 315 SE 7* Street, Fort Lauderdale, FL 33301• EFTA00805512 among other things, the litigation privilege. Accordingly, an award of a

uary 27, 2014, this Honorable Court granted summary judgment in favor of Epstein on both counts. This Court entered an Order reflecting same on May Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, EL 33301 EFTA00805510 19, 2014. A true and correct copy of the Order is attached hereto as "Exhibit B.

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this June 2, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys

2 Fort Lauderdale, Florida 33301 Fred Haddad Es I Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'itHa dColeman uire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr. W. Chester Brewer, Jr., P.A. 250 S. Australian Avenue Suite

LT "II" EFTA00805524 The Court thoroughly reviewed Levin, Midcllebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe v. Foreman, 38 Fla. L. Weekly D1540 (July 17, 2013). These case

underlying proceeding. Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 SO. 2d 606, 608 (Fla. 1994). This position was reaffirmed in Echevarria. In Wolfe, the Third District Court of Appeal, quoting in large part from Echevarria, found specifically that the litigation privilege applies to m

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613837 and case law, granted Epstein's Motion. Days later, Edwards filed a Motion for

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys for Epstein 6

2007), as well as reviewing the application and analysis of those cases in Wolfe v. Foreman, 38 Fla. L. Weekly D1540 (July 17, 2013), correctly 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613838 concluded that all actions occurring during the course of a judicial proceeding,

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) At

King, anything that% being 10 alleged here that goes outside of the broad II spectrum that I have read into the record that has 12 its genesis in Echevarria and was quoted by the 13 Wolfe Third District Court of Appeal opinion? 14 MR. KING: There's nothing alleged. 15 Mr. Edwards' testimony, though, wa

da Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the application and analysis of those cases in Wolfe

& MCMULLEN, P.A. 123 South Calhoun Street P.O. Box 391 (zip 32302) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale Florida 33301 25 EFTA00613614

h FL 33401 /s/ John Beranek JOHN BERANEK Fla. Bar No.: 0005419 AUSLEY & MCMULLEN, P.A. 123 South Calhoun Street P.O. Box 391 (zip 32302) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale Florida 33301 25 EFTA0061361

Beranek JOHN BERANEK Fla. Bar No.: 0005419 AUSLEY & MCMULLEN, P.A. 123 South Calhoun Street P.O. Box 391 (zip 32302) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale Florida 33301 25 EFTA00613614

to allow a party to `prosecut[e] or defend[] a lawsuit without fear of having to defend their actions in a subsequent civil action for misconduct.' Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So.2d 380, 384 (Fla. 2007); see also Levin, 639 So.2d at 608 C[A]bsolute immunity must be afforde

OURT: Mr. King, anything that's being alleged here that goes outside of the broad spectrum that I have read into the record that has its genesis in Echevarria and was quoted by the Wolfe Third District Court of Appeal opinion? MR. KING: There's nothing alleged. (T. 53-54). Accordingly, as explicitly stat

requests this Court to infer about Wright as a result of its citation in Levin, the Florida Supreme Court subsequently made it abundantly clear in Echevarria that "the nature of the underlying dispute simply does not matter," and mandated that the litigation privilege be broadly applied "across the board

32302) Tallahassee, FL 32301 Telephone: Facsimile: ( (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 I l 26 EFTA00589646

05419 AUSLEY & MCMULLEN, P.A. 123 South Calhoun Street P.O. Box 391 (zip 32302) Tallahassee, FL 32301 Telephone: Facsimile: ( (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 I l 26 EFTA00

ed directly to the litigation. Under well-established Florida Supreme Court precedent, the litigation privilege applies to all causes of action. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007); Levin, Middlebrooks, Moves & Mitchell, M. v. U.S. Fire Ins. Co., 639 So.

ct occurring during the course of a judicial proceeding . . . so long as the act has some relation to the proceeding." Levin, 639 So. 2d at 608. In Echevarria, the Court reiterated its broad application of privilege "applies in all causes of action, statutory as well as common law." Echevarria, 950 So. 2d

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell, M. v. U.S. Fire Ins. Co., 639 S

2301 Telephone: (850) 224-9115 Facsimile: 5 222-7560 (secondary) /s/ 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 54.337.3716 facsimile 25 EFTA00714948

EN, M. 123 South Calhoun Street ■. Box 391 (zip 32302) Tallahassee, FL 32301 Telephone: (850) 224-9115 Facsimile: 5 222-7560 (secondary) /s/ 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

ct occurring during the course of a judicial proceeding . . . so long as the act has some relation to the proceeding." Levin, 639 So. 2d at 608. In Echevarria, the Court reiterated its broad application of privilege "applies in all causes of action, statutory as well as common law." Echevarria, 950 So. 2d

ed directly to the litigation. Under well-established Florida Supreme Court precedent, the litigation privilege applies to all causes of action. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007); Levin, Middlebrooks, Moves & Mitchell,.. v. U.S. Fire Ins. Co., 639 So. 2

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell,.. v. U.S. Fire Ins. Co., 639 So.

ce, to all parties on the attached service list, this June 2, 2014. /s/ Ionia I laddad 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) Attorneys for Epstein Tonja Haddad, M. •

ey J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 Fred Haddad, Esq. 1 Financial Plaza, Ste. 2612 Ft. Lauderdale„FL 33301 Tonja Haddad Coleman, Esq. 315 SE 7th Si, Ste. 301 Ft. Lauderdale, FL 33301 William B. King, Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Burlington &

HIAIT "B" EFTA00617998 The Court thoroughly reviewed Levin, Middlebrooks, Moves & Mitchell v. US. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe v. Foreman, 38 Fla. L. Weekly D1540 (July 17, 2013). These case

underlying proceeding. Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 SO. 2d 606, 608 (Fla. 1994). This position was reaffirmed in Echevarria. In Wolfe, the Third District Court of Appeal, quoting in large part from Echevarria, found specifically that the litigation privilege applies to m

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, • • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00583040 and case law, orally granted Epstein's Motion. Days later, Edwards f

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 11, 2014. /s/ Ionia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimil

da Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the application and analysis of those cases in Wolfe

King, anything that's being 10 alleged here that goes outside of the broad 11 spectrum that I have read into the record that has 12 its genesis in Echevarria and was quoted by the 13 Wolfe Third District Court of Appeal opinion? 14 MR. KING: There's nothing alleged. 15 Mr. Edwards' testimony, though, wa

Pursuant to §57.105 of the Florida Statutes, and grant such other and further relief as deemed necessary and proper. Respectfully submitted, /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE t h Street Suite 301 Fort Lauderdale, Florida 33301 95

f the Florida Statutes, and grant such other and further relief as deemed necessary and proper. Respectfully submitted, /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE t h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.37

was filed and were related to the judicial proceedings, the abuse of process cause of action was completely barred. Id (emphasis added).; see also Echevarria, McCalla, Rayner, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins

act occurring during the course of a judicial proceeding . . so long as the act has some relation to the proceeding." Levin, 639 So. 2d at 608. In Echevarria, the Court reiterated its broad application of privilege "applies in all causes of action, statutory as well as common law." Echevarria, 950 So. 2d

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

MR. BREWER: So let's get into the Wolfe case. That's where we're headed next. And really there's a trilogy of cases. There's the Levin case, the Echevarria case, if I'm somewhere close to pronouncing that correctly, and the Wolfe case. All of them deal with litigation privilege which dates back to 191

•• "THE COURT: This deals with the litigation privilege?" The attorney then goes on to say, "Yes, sir, it does deal with litigation privilege. Echevarria also deals with the litigation privilege. Delmonico stands for the proposition that the issues with regard to privilege are some issues of law for

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639

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

ss and malicious prosecution claims, and also finding that Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe provided "binding precedent in this area of law." (R. 1203).2 Fi