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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 pertained to his
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
rocess 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 of process
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
994) 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 long as th
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 Foreman and the Fourth Amended Counterclaim

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONMaria Farmer
PERSONScott Rothstein
PERSONWolfe
PERSONJack Goldberger
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONTonja Haddad Coleman
PERSON
George Mitchell
PERSONJack Scarola
PERSONLevin
PERSONJane Doe
PERSONWright
PERSONEchevarria
PERSON
Scarlett Johansson
PERSON
McCalla
PERSONBarrett & Frappier
ORGANIZATION
Middlebrooks
PERSON