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the Court heard argument solely as to the litigation privilege. 2 EFTA00808206 the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it perta
tein. Epstein subsequently dismissed his Complaint without prejudice. The counter-claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation privilege app
use of process claims filed against Epstein by the appellant, Bradley J. Edwards. The trial judge relied in part upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse
tioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me
8 (Fla. 1994) and Echevarria, McCalla, Rayner, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as the application of those cases in Wolfe v. Foreman, 38 Fla. L. Weekly D1540 (July 17, 2013), is bound to conclude that all actions occurring during the course of a judicial proceeding, so
o the proceeding, are absolutely privileged. This absolute immunity afforded to Epstein pursuant to the litigation privilege appears on the face of the Fourth Amended Counterclaim as filed by Edwards. Further, during the hearing before this Court, Counter-Plaintiff Edwards candidly conceded that all of the allegations upon wh
Entities connected to both Wolfe and the Fourth Amended Counterclaim

Jeffrey Epstein
PERSON
Donald Trump
PERSON
George W. Bush
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
Bill Clinton
PERSONTonja Haddad Coleman
PERSONMaria Farmer
PERSON
Foreman
PERSONJack Goldberger
PERSONJack Scarola
PERSONWright
PERSONLevin
PERSONEchevarria
PERSONPalm Beach Lakes Blvd
LOCATION
McCalla
PERSON
Adler
PERSONFlorida Bar
ORGANIZATION