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PHERD, C.J., specially concurring. The only remarkable thing about this case is its existence. As the managing attorney of the Miami office of The Florida Bar explained to Mr. Wolfe (himself a licensed Florida attorney), when he refused to accept staff counsel's initial rejection of his Bar complaint agai
re thus absolutely privileged under Florida law. LEGAL ANALYSIS Our standard of review of the trial court's judgment on the pleadings is de novo. Martinez v. Fla. Power & light WeStiawNeXI @ 2013 Thomson Reuters. No claim to original U.S. Government Works. 2 EFTA00612145 Haddad, Tonja 8/26/2013 Fo
00175324 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 7 of 7 v. Epstein, et al. By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bcIcl w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 moikeebdclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive,
the "predicate acts" specifically identified in §2255. "18 U.S.C. §2255 gives victims of sexual conduct who are minors a private right of action." Martinez v. White 492 EFTA00175344 Case 9:08-cv-80811-KAM Document 47 Entered on FLSD Docket 03/12/2009 Page 7 of 21 v. Epstein, et al. age v. Husban
aintiffs. Without attempting to make any connection to the asserted violation of the CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and Department of Justice regulations by representing Epstein's employees in civil litigation after Movant retired from the United States Att
re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi
aintiffs. Without attempting to make any connection to the asserted violation of the CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and Department of Justice regulations by representing Epstein's employees in civil litigation after Movant retired from the United States Att
re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judic
l chain titled Things to do in West Palm 11/4/2008 Villafafia Senior Email thanking Villafatia for her 11/3/08 email advising she spoke with the Florida Bar 11/4/2008 Correspondence from Florida Bar Ethics Counsel regarding Florida Ethics Rules involved in distributing victim notification letters 11/1
e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2
Entities connected to both Florida Bar and Martinez

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSONJack Goldberger
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
George W. Bush
PERSONLeon Black
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Scarlett Johansson
PERSONScott Rothstein
PERSON
Alexander Acosta
PERSON
Virginia Giuffre
PERSONRobert C. Josefsberg
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON