Epstein Secrets

) 6, 9 Valdes v. GAB Robins, 924 So. 2d 862 (Fla. 3d DCA 2006) 7 Volusia County v. Aberdeen at Ormond Beach, M., 760 So. 2d 126 (Fla. 2000) 2 Wolfe v. Foreman, 128 So. 3d 67 (FIa. 3d DCA 2013) passim Wright v. Yurko, 446 So. 2d 1162 (Fla. 5th DCA 1984) 19, 20, 21 iii EFTA00589620 PRELIMI

16 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory

6, 9 Valdes v. GAB Robins, 924 So. 2d 862 (Fla. 3d DCA 2006) 7 Volusia County v. Aberdeen at Ormond Beach, L.P., 760 So. 2d 126 (Fla. 2000) 2 Wolfe v. Foreman, 128 So. 3d 67 (FIa. 3d DCA 2013) passim Wright v. Yurko, 446 So. 2d 1162 (Fla. 5th DCA 1984) 19, 20, 21 iii EFTA00714923 PRELIM

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory

sconduct," we are obligated to conclude that the act complained of here -- the filing of the complaint — is protected by the litigation privilege. Wolfe v. Foreman, 128 So. 3d 67, 68 (Fla. 3d DCA 2013) (emphasis added). Additionally, the Wolfe decision was recently cited with approval and relied upon

d 1054, 1056 (Fla. 4th DCA 1999). See also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006); Fridovich v. Fridovich, 598 So. 2d 65 (Ha. 1992) (stating that the litigation privilege "arises immediately upon the doing of any act required or permitted by law in the

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory

TA00606518 10 1 Appeals and, in fact, the Fourth District Court Of 2 Appeals. 3 THE COURT: One thing I wanted to interrupt 4 you on is this Wolfe case and its current status 5 and the -- I'll call the -- I'll call it the 6 Edwards side to make things be easier. But the 7 Edwards side has

n of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 Sold. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of whether a person

accusing Olson of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 Sold. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of wh

le cause issue was one for the jury. However, this Court granted summary judgment in favor of Epstein based on the litigation privilege, relying on Wolfe v. Foreman, 128 So.3d 67 (Fla. 3d DCA 2013). Accordingly, Final Judgment was entered in favor of Epstein. 2 EFTA00613502 Edwards appealed the su

accusing Olson of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 So2d. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of wh

n of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 So2d. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of whether a person

2 F.Supp.2d 626 (D. N.J. 2011). 9 Watts v. Gerking, 111 Or. 641, 228 P. 135 (1924) 10 Wiggs v. Farmer, 205 Va. 149, 135 S.E.2d 829 (1964) 10 Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). 1 Young v. First State Bank, Watonga, 628 P.2d 707 (Okla. 1981). 10 OTHER AUTHORITIES Cal. Civ.

169 So. 3d 1204 (Fla. 4th DCA 2015). 2 EFTA00610602 Flynn v. Okafor, No. 03AP-1232, 2004 WL 1607024 (Ct. App. Ohio 2004). . 9, 10 Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) 3 Gainer v. Portfolio Recovery Assoc., LLC, 571 F.Supp.2d 1273 (S.D. Fla. 2008)2 Glenn v. Hoerner Boxes, Inc., 211 F.Su