Epstein Secrets

e shoehorn her claim within section (2). Instead, she can rely on (3), which is “a ‘catch-all’ phrase that allows courts to award “other relief.” Freeman v. First Union Nat. Bank, 865 So.2d 1272, 1276 (Fla. 2004). The intent of this provision was “to facilitate the use of the other remedies provided i

e Doe’s argument that “equity will do what ought to be done.” Jane Doe’s Motion to Restrain Fraudulent Transfer of Assets at 17 (citing Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000)). The only question then is “what ought to be done?” Case 9:08-cv-80119-KAM Document 217 Entered on

legal, equitable, secured, or unsecured."); Fla. Stat. Ann. § (defining creditor protected by the act as "a person who has a claim"). See generally Freeman v. First Union Nat. Bank, 865 So.2d 1272, 1277 (Fla. 2004) (noting that the definition of 13 Case 9:08-cv-80119-KAM Document 165 Entered on

Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 18 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe

legal, equitable, secured, or unsecured."); Fla. Stat. Ann. § (defining creditor protected by the act as "a person who has a claim"). See generally Freeman v. First Union Nat. Bank, 865 So.2d 1272, 1277 (Fla. 2004) (noting that the definition of 13 EFTA00234883 Case 9:08-cv-80119-KAM Document 165

7 Case 9:08-cv-80119-KAM Document 165 Entered on FLSD Docket 06/19/2009 Page 18 of 41 CASE NO: 08-CV-80119-MARRA/JOHNSON be done." Sterling v. Brevard County, 776 So.2d 281, 284 (Fla. Ct. Apps. 2000). The Court should therefore also exercise its equitable powers to impose the same remedies that Jane Doe