Epstein Secrets

overy motion. The facts underlying that action are briefly as follows: Scott Rothstein was the managing partner and CEO of Rothstein, Rosenfeldt and Adler ('RRA"), a 70-lawyer firm in Fort Lauderdale, Florida. Balin Aft Ex. A, Ex. 1 ("Rothstein Information") ¶¶ 1-2; id., Ex. 2 (Amended Complaint for D

Church of Scientology of Calif, Inc., 444 So.2d 442 (Fla. Dist. Ct. App. 1983) 18 Damiano v. Sony Music Entm 'I, Inc., 168 M. 485 (M. 1996) 27 Della-Donna v. Nova University, Inc., 512 So.2d 1051 (FIa. Dist. Ct. App. 1987) 18 DePalma v. DePalma, 538 So.2d 1290 (FIa. Dist. Ct. App. 1989) 21 E.I. Du

eme Action and does not Indeed, Epstein's settlement of the three suits legally km him from ever making such a claim for malicious prosecution. See Della-Donna v. Nova University, Inc., 512 So.2d 1051, 1055 (Fla. Dist. Ct. App. 1987) ("a bona fide termination favorable to plaintiff does not encompass a term

taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein. Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fistos, & Lehrman to

verted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 24 1051, 1055 (Fla. 4th DCA 1987). SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epstein states that

taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein, Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fistos, & Lehrman to

erted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt., Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). EFTA00292563 SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epst