Epstein Secrets

M Document 177 Entered on FLSD Docket 06/06/2012 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a mot

omment by attorney Tonja Haddad to attorney Jack Scarola — is neither pertinent, significant, nor authoritative to the issues before this Court. Ms. Haddad's comment to Mr. Scarola does not pertain to plea negotiations and therefore her comment is irrelevant. The facts leading up to Ms. Haddad's commen

ts with regards to the g issue whether the litigation privilege bars a 9 malicious prosecution claim. And I have cited to 10 the case Olson vs. Johnson, 961 Sold. 356, the 11 Second DCA's opinion in 2007, after both Levin and 12 Echevarria. And it holds that malicious 13 prosecution claims are

dled those cases I 9 believe to their conclusion, at or near the time 10 that I left that division two years ago or so. 11 Okay. So are you Ms. Haddad? 12 MS. HADDAD: I am. 13 THE COURT: Will you be arguing on behalf 14 Mr. Epstein? 15 MS. HADDAD: No, Judge. I don't have -- 16 Mr. Brewer wi

Acts committed prior to the filing of the complaint may not, in some cases, enjoy the broad protection of the privilege. For example, in Olson v. Johnson, 961 So.2d 356, 360 (Fla. 2d DCA 2007), the court found that the litigation privilege did not protect the three women who allegedly filed a police

Haddad, Tonja 8/26/2013 For Educational Use Only Wolfe v. Foreman, — So.3d — (2013) 38 Fla. L. Weekly D1540 2013 WL 3724763 Only the Westlaw citation i

ts with regards to the 8 issue whether the litigation privilege bars a 9 malicious prosecution claim. And 2 have cited to 10 the case Olson vs. Johnson, 961 So2d. 356, the 11 Second DCA's opinion in 2007, after both Levin and 12 Echevarria. And it holds that malicious 13 prosecution claims are

dled those cases I 9 believe to their conclusion, at or near the time 10 that I left that division two years ago or so. 11 Okay. So are you Ms. Haddad? 12 MS. HADDAD: I am. 13 THE COURT: Will you be arguing on behalf 14 Mr. Epstein? 15 MS. HADDAD: No, Judge. I don't have -- 16 Mr. Brewer wi