Epstein Secrets

ed directly to the litigation. Under well-established Florida Supreme Court precedent, the litigation privilege applies to all causes of action. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007); Levin, Middlebrooks, Moves & Mitchell, M. v. U.S. Fire Ins. Co., 639 So.

ct occurring during the course of a judicial proceeding . . . so long as the act has some relation to the proceeding." Levin, 639 So. 2d at 608. In Echevarria, the Court reiterated its broad application of privilege "applies in all causes of action, statutory as well as common law." Echevarria, 950 So. 2d

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell, M. v. U.S. Fire Ins. Co., 639 S

ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00589625 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle

King, anything that% being 10 alleged here that goes outside of the broad II spectrum that I have read into the record that has 12 its genesis in Echevarria and was quoted by the 13 Wolfe Third District Court of Appeal opinion? 14 MR. KING: There's nothing alleged. 15 Mr. Edwards' testimony, though, wa

da Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the application and analysis of those cases in Wolfe

resolved in favor of the Defendant. This Steinberg case appears to be analogous to the Olson case upon which Edwards relied in his argument against Summary Judgment; an argument which was rejected by this Court. Transcript of Motion for Summary Judgment hearing, p. 58. The Olson case, just as this Court correct

ment in an action for abuse of process on the basis of absolute immunity and on the authority of Levin). As such, this Court was correct in granting Summary Judgment in 3 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613839 favor of Epstein. Edwards, despite his interminable filings,

ct occurring during the course of a judicial proceeding . . . so long as the act has some relation to the proceeding." Levin, 639 So. 2d at 608. In Echevarria, the Court reiterated its broad application of privilege "applies in all causes of action, statutory as well as common law." Echevarria, 950 So. 2d

ed directly to the litigation. Under well-established Florida Supreme Court precedent, the litigation privilege applies to all causes of action. See Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007); Levin, Middlebrooks, Moves & Mitchell,.. v. U.S. Fire Ins. Co., 639 So. 2

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell,.. v. U.S. Fire Ins. Co., 639 So.

ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00714928 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle

MR. BREWER: So let's get into the Wolfe case. That's where we're headed next. And really there's a trilogy of cases. There's the Levin case, the Echevarria case, if I'm somewhere close to pronouncing that correctly, and the Wolfe case. All of them deal with litigation privilege which dates back to 191

•• "THE COURT: This deals with the litigation privilege?" The attorney then goes on to say, "Yes, sir, it does deal with litigation privilege. Echevarria also deals with the litigation privilege. Delmonico stands for the proposition that the issues with regard to privilege are some issues of law for

submits that the trial court's Order granting his Motion for Summary Judgment was proper, as the binding decisions by the Florida Supreme Court in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) and Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639

ecution, and that Wolfe is in conflict with pre-existing law on this issue. See 5 EFTA00613594 Brief, p. 6. Appellant does, however, concede that Summary Judgment was proper as to his Abuse of Process claim, see Brief, p. 10, n.2, and that there are no disputed issues of fact presented. Brief, p. 10. Appelle

to allow a party to `prosecut[e] or defend[] a lawsuit without fear of having to defend their actions in a subsequent civil action for misconduct.' Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So.2d 380, 384 (Fla. 2007); see also Levin, 639 So.2d at 608 C[A]bsolute immunity must be afforde

OURT: Mr. King, anything that's being alleged here that goes outside of the broad spectrum that I have read into the record that has its genesis in Echevarria and was quoted by the Wolfe Third District Court of Appeal opinion? MR. KING: There's nothing alleged. (T. 53-54). Accordingly, as explicitly stat

requests this Court to infer about Wright as a result of its citation in Levin, the Florida Supreme Court subsequently made it abundantly clear in Echevarria that "the nature of the underlying dispute simply does not matter," and mandated that the litigation privilege be broadly applied "across the board

based on the undeniable holdings in Wolfe and the cases cited therein, Epstein's actions were absolutely protected by the litigation privilege and Summary Judgment was properly granted. Additionally, Appellant attempts to support his position by referencing the most recent Florida Supreme Court decision apply

da Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the application and analysis of those cases in Wolfe

King, anything that's being 10 alleged here that goes outside of the broad 11 spectrum that I have read into the record that has 12 its genesis in Echevarria and was quoted by the 13 Wolfe Third District Court of Appeal opinion? 14 MR. KING: There's nothing alleged. 15 Mr. Edwards' testimony, though, wa

ment in an action for abuse of process on the basis of absolute immunity and on the authority of Levin). As such, this Court was correct in granting Summary Judgment in favor of Epstein. Edwards, despite his interminable filings, has not identified one Florida case decided either after the Wolfe decision or the

resolved in favor of the Defendant. This Steinberg case appears to be analogous to the Olson case upon which Edwards relied in his argument against Summary Judgment; an argument which was rejected by this Court. Transcript of Motion for Slummy Judgment hearing, p. 58. The Olson case, just as this Court correctl