Epstein Secrets

urring during the course of a judicial proceeding, if those acts bear some relation to the proceeding. Edwards urged the Court to fmd that Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA 2007), is in conflict with Wolfe, thereby allowing the Court to find that the privilege does not apply. However, Olson

ation of the case, although many nominal offers have been accepted by the courts as made in good faith. See Fox v. McCaw Cellular Communications of Florida, Inc., 745 So. 2d 330 (Fla. 4th DCA 1998); Neptune Beach v. Smith, 740 So. 2d 25, 27 (Fla. 1st DCA 1999). In the case at hand, Edwards filed a Countercla

pier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) 12 Jackson v. BellSouth

ABLE OF CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

Document 462 Entered on FLSD Docket 02/04/2010 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

ope of discoverable information to those matters which are relevant to a claim or defense in the lawsuit. Dellacasa, LLC v. John Moriarty & Ass. Of Florida, Inc., 2007 WL 4117261 at *3 (S.D. Fla. 2007). Courts have long held that "[w]hile the standard of relevancy [in discovery] is a liberal one, it is not s

urring during the course of a judicial proceeding, if those acts bear some relation to the proceeding. Edwards urged the Court to fmd that Olson v. Johnson, 96] So. 2d 356 (Fla. 2d DCA 2007), is in conflict with Wolfe, thereby allowing the Court to fmd that the privilege does not apply. However, Olson

ation of the case, although many nominal offers have been accepted by the courts as made in good faith. See Fox v. McCaw Cellular Communications of Florida, Inc., 745 So. 2d 330 (FM. 4th DCA 1998); Neptune Beach v. Smith, 740 So. 2d 25, 27 (Ha. 1st DCA 1999). In the case at hand, Edwards filed a Counterclaim

Document 462 Entered on FLSD Docket 02/04/2010 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-8089

ope of discoverable information to those matters which are relevant to a claim or defense in the lawsuit. Dellacasa, LLC I. John Moriarty & Ass. Of Florida, Inc., 2007 WL 4117261 at *3 (S.D. Fla. 2007). Courts have long held that "[w]hile the standard of relevancy [in discovery] is a liberal one, it is not s

ier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) 12 Jackson v. BellSouth

F CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

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

F CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevar

proceeding, a cause of action sounding in malicious prosecution may still be viable. See Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992); Olson v. Johnson, 961 So. 2d 356 (Ha. 2d DCA 2007). Moreover, the Florida Supreme Court judiciously pointed out in Levin that "other tortious conduct during litiga

just as occurred in the Wolfe case, mandating Summary Judgment. Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013); American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999). See also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 12