Epstein Secrets

conducted an analysis of the seminal cases upon which Appellee relies in support of his assertion that the trial court's ruling was proper; Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. United States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & 9

ional Association, 141 So. 3d 754 (Fla. 4th DCA 2014) 2 LatAm Invests., LLC v. Holland & Knight, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994) passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbil

licious prosecution or abuse of process; 19 rather, it would be through the court with 20 contempt proceedings, perhaps. It would be 21 through the Florida Bar for, you know, 22 inappropriate actions taken by an attorney. It 23 could be perjury for a litigant which would be 24 handled by the state. 25

s. Under Florida law, there is no immunity for acts undertaken in judicial proceedings that bear no relation to those proceedings. See, e.g., Levin, Middlebrooks, Mahie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 616, 608 (1994). It is for a fact finder to determine whether Edwards' ac

ar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christopher E. Knight Florida Bar. No. FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, 14th floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: Facsimile: Attorneys for

force its orders, to conduct its business in a proper manner, and to protect the court from acts obstructing the administration of justice." Levin, Middlebrooks, Mabie, Maves & Mitchell, P.A. v. United States Fire Ins. Co., 639 So.2d 606, 608-09 (Fla. 1994). Most recently, the Supreme Court in Bitterman v.

ry of a video deposition to the media. See infra for argument on media not having a right to pretrial discovery. 13. Rule 4-3.6, Rules Regulating the Florida Bar, states, in pertinent part: (a) Prejudicial Extrajudicial Statements Prohibited. A lawyer shall not make an extrajudicial statement that a reasonab

rida in 1907 to provide legal immunity for actions that occur in judicial proceedings. Myers v. Hodges, 53 Fla. 197, 44 So. 357 (1907). In Levitt, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So.2d 606, 608 (Fla.I994), the Florida Supreme Court extended the litigation pri

PHERD, C.J., specially concurring. The only remarkable thing about this case is its existence. As the managing attorney of the Miami office of The Florida Bar explained to Mr. Wolfe (himself a licensed Florida attorney), when he refused to accept staff counsel's initial rejection of his Bar complaint agai

ed to the proceedings, the litigation privilege applied to both the abuse of process 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.

ons of dollars and to fund the RRA Pont Scheme. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware t

orney General, approved the request. (See Ex. 10.) I then applied to the Court for an Order compelling Jane Doe 2's testimony. U.S. District Judge Middlebrooks granted the Application on April 16, 2007. (Ex. 11.) II. After receiving Judge Middlebrooks' Order, Mr. Eisenberg then asked whether Jane Doe 2 c

in light of his clear statements that he represented Jane Doe 2, I could not directly contact or "confer" with Jane Doe 2 without running afoul of the Florida Bar rules. 8. I continued to converse with Mr. Eisenberg about having Jane Doe 2 appear for a voluntary interview, which continuously delayed the inve

igation privilege argument that your Honor 10 has heard repeatedly from opposing counsel. It 11 is based upon the Court's decision in Levin, 12 Middlebrooks which describes a broad litigation 13 privilege, applicable in the context of 14 legitimate claims. 15 The attempt to apply the litigation 16

ds had subpoenaed Ghislaine Maxwell, that 21 she was a good person that did nothing wrong. 22 And Jeffrey Epstein filed a complaint with the 23 Florida Bar against Bradley Edwards raising 24 allegations that Edwards was directly involved 25 in the Rothstein wrongdoing, the same ibIA"ktiafifirr--- e8

ce Fisher, Assistant Attorney General. (See Ex. B.) I then applied to the Court for an Order compelling Jane Doe 2's testimony. U.S. District Judge Middlebrooks granted the application on April 16, 2007. (Ex. 6.) 12. After learning of Judge Middlebrooks' Order, Mr. Eisenberg asked whether Jane Doe 2 could

in light of his clear statements that he represented Jane Doe 2, I could not directly contact or "confer" with Jane Doe 2 without running afoul of the Florida Bar rules (e.g., R. Regulating Fla. Bar 4-4.2) and 28 U.S.0 § 530B. 9. I continued to converse with Mr. Eisenberg about having Jane Doc 2 appear for a

nformed about subsequent developments in Rothstein’s prosecution. See Letter attached hereto as Exhibit | 92. Jeffrey Epstein filed a-complaint with the Florida Bar against Bradley Edwards, Esa, raising allegations that Edwards and others were involved in the wrongdoing of Scott Rothstein. After investigating the

or other tortious behavior, suéh as tortious interference with business relationship, so long as act has some relationship to proceeding, See Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So, 2d 606 (Fla. 1994). The immunity afforded to statements made during the course