Epstein Secrets

ein." So, Epstein cannot claim entitlement to fees because he cannot prove he has beaten his Proposal, or even that he has equaled his Proposal. As the Florida Supreme Court explained in invalidating Proposals which include equitable claims, the rule and statute require a pure mathematical comparison between offer and re

ls to satisfy the particularity requirement if an ambiguity could reasonably affect the offeree's decision to accept or reject. See Nationwide Mut. Fire Ins. Co. v. Pollinger 42 So.3d 890, 891 (Fla. 4th DCA 2010). As the Supreme Court has noted State Farm Mut. Auto Ins. Co. v. Nichols, 932 So.2d 1067, 1079

ranscript at 50, 54, 91, 100-104, 114, 126,-127, 155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is no

adverse party to show that the communication was not privileged. Leithauser v. Harrison, 168 So. 2d 95 (Fla. 2d DCA 1964); see also Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, 192-93 (Fla. 4th DCA 1991) ("[N]othing in the record indicates that any documents are protected by the attorney/client p

ing and a lengthy hearing, this Court ruled that the litigation privilege barred Edwards's causes of action against Epstein. The Court, in applying the Florida Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCa

hevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 S

ed in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), explained what is covered by the work product privilege: [T]hose documents, pictu

work-product privilege extends only to "materials in question [which]were prepared in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (F

ing and a lengthy hearing, this Court ruled that the litigation privilege barred Edwards's causes of action against Epstein. The Court, in applying the Florida Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCa

Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 S