Epstein Secrets

delay by the first court, that warrant the denial of a stay. Thus, absent any such special circumstances, a trial court abuses its discretion in 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611632 refusing to grant a stay based on the principle of priority." Spac

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ 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 95

Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and on November 12, 2015, Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611631 the Fourth District Court of Appeal reversed this Court's ruling a

e and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ 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 954.467.1223 954.337.37

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 27, 2013. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Ton'a Haddad, PA (facsimile) Attorneys for Epstein EFTA00598340 SERVICE LIST CASE NO. 502

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 27, 2013. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Ton'a Haddad, PA (facsimile) Attorneys for Epstein EFTA00598340 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG J

PA Marc Nurik, Esq. Brac lwards, E . Farmer Jaffe Weissing Edwards Fistos Lehrman Fred Haddad, Es Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. EFTA00598341

, 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Fla. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair prejudice, confusion of the

iff Bradley Edwards's Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a t

Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a true and correct copy o

he onus of supplying the information or documents is inordinate." Topp Telecom, Inc. v. Atkins, 763 So. 2d 1197, 1199 (Fla. 4th DCA 2000). See also Allstate Ins. Co. v. Boecher, 733 So. 2d 993, 994 (Fla.1999) (noting the lack of "affidavits, depositions or other sworn testimony in the record to support Allstate's

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

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an

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

d." Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla.1999). "This rule applies in cases of summary judgments as well." Landis v. Allstate Ins. Co., 546 So. 2d 1051, 1053 (Fla. 1989); see also Rivernider, supra (holding that although trial judge erred in granting summary judgment based upon the