Epstein Secrets

where a malicious prosecution for criminal prosecution can be actionable "per se," a plaintiff in a civil action must prove the damages sought. See Adler v. Segal, 108 So. 2d 773, 775 (Fla. 3d DCA 1959)(malicious prosecution action based on acquittal in underlying criminal prosecution; court held that

as 11 EFTA00805452 those applicable in actions for defamation ... ."); compare Burchell v. Bechert, 356 So. 3d 377 (Fla. 4th DCA 1978)(applying Adler's holding but dicta because court already determined damages element met by record evidence of attorneys' fees incurred in defending the lawsuits).

nded Counterclaim and November 29, 2011, Second Amended Counterclaim, he characterized it as a "highly defamatory press release." (D.E. 388, ¶ 13) (D.E. 413, ¶ 9). • January 6, 2012: In Answers to Interrogatories, Edwards stated that: "Bradley Edwards has described the special damages he has susta

ge Ray that impose restrictions on the possession of electronic data produced in response to a subpoena for emails from the Rothstein, Rosenfeldt, Adler law firm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793426 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 27 of 97 1 2 3 4 5

Did you ever learn that privilege was being asserted with respect to the production of any emails that were contained on a Rothstein, Rosenfeldt, Adler server? A Separate from a conversation with my attorneys, I don't recall. Q Are you aware, as you sit here today, that federal bankruptcy Judg

the issue of his knowledge and possession of the disc. (Apr. Tr. 36:2-9.) The Show Cause Order also provided for the filing of sworn declarations. (D.E. 6366,91 5 i.v.) Specifically, it provides: Unless otherwise ordered, the direct testimony of each witness, except adverse, hostile or rebuttal witn

time in the schedule to depose Mr. Rothstein. The deposition of Scott Rothstein was taken in the bankruptcy proceeding of Rothstein, Rosenfeldt and Adler ("RRA"), but not completed, from December 12, 2011 through December 7 EFTA00808032 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXM

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

mplaint") [D.E. 4] to assert ten counts against the Defendants, some against Mr. Russell Adler, individually, and the remainder, jointly against Mr. Adler and his wife, Miss Katie Adler. The first six counts are to avoid alleged fraudulent transfers, the seventh alleges breach of fiduciary duty agains

same time that the Defendants received the Apartment Transfers, Mr. Adler also received a $100,000 year Increase in his sa'ary from RRA. [D.E. 4 and D.E. 67 at'928]. In addition to the Apartment Transfers, the Defendants received a total of $220,000 in Cash Transfers. Of the $220,000 received by the