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he pending discovery 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 Compl
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
s allegedly 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, & Lehr
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
s allegedly 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, & Lehr
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
Entities connected to both Rosenfeldt and Della-Donna
Scott Rothstein
PERSON
Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Adler
PERSONJack Goldberger
PERSONJack Scarola
PERSONMaria Farmer
PERSONPalm Beach Lakes Blvd
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
Weissing
PERSONAtterbury
ORGANIZATIONComplex Litigation
ORGANIZATIONMarc S. Nurik
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONFederal Court
ORGANIZATIONAnn Sanchez
PERSONthe Florida Rules of Civil Procedure
ORGANIZATIONSearcy Denney Scarola
PERSON
Farmer, Jaffe
ORGANIZATIONValdes
PERSON