Epstein Secrets

al damages such as one dollar. Source: Abuse of Process: Valdes v. GAB Robins N. Am. Inc., 924 So. 2d 862 (Fla. 3d DCA 2006); S & I Investments v. Payless Flea Market, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010). Nominal damages are sufficient to recover on an action for abuse of process. See Stole,. v. Levinson, 394

case are Jeffrey Epstein (via video deposition), Bradley Edwards, Scott Rothstein (via video deposition), and Mr. Edwards' clients (L.M., E.W. and Jane Doe). Source: Florida Standard Jury Instruction (Civil) 201.1 Given Given as Modified Denied Withdrawn 5 EFTA00804794 PLAINTIFF/COUNTER-DEFENDA

ired to prove harm. See, e.g., Bortell v. White Mountains Ins. Group, Ltd., 2 So.3d 1041, 1047 (Fla. 4th Dist. Ct. App. 2009); S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4'h Dist. Ct. App. 2010). Epstein was not harmed by Rothstein's misrepresentations to other people that he knew nothing abo

atement of Undisputed Facts. 12 EFTA00725980 In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising an

Inc. v. Euroclassics Ltd., 502 So.2d 959 (Fla. Dist. Ct. App. 1983) 21 Russman v. Bd. of Ed., 260 F.3d 114 (2d Cir. 2001) 13 S&I Investments v. Payless Flea Market, Inc., 36 So.3d 909 (Fla. Dig. Ct. App. 2010) 18 Saxton v. Arkansas Gazette Co., 264 Ark. 133 (1978) 29 Smith v. Moore, 31 III3d 628, 818 2d 603 (2

that Rush had waived sa applicable reporter's privilege by disclosing brief portions of the Epstein interview to third parties (Balin Aff. Ex. K (Jane Doe's Response in Opposition to Motion of Daily News, to Quash Subpoena), at 6-13) — the same exact waiver argument he makes here. The federal District

plaintiff suffered damage.” S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla, 4" Dist. Ct. App. 2010)

ards filed a civil sot against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, LM. v. Epstein, (Exhibit “V”). 3 47. Jane Doe’s federal complaint indicated that she sought damages of more than $50,000,000. Listing the amount of damages sought in the complaint was in accord wit