Epstein Secrets

County 41. NEPTUNE'S INVESTMENT HOLDING C 5640 Taylor Rd Ste 5 Naples, FL 34109-2300 Collier County

ach, FL 32170-0578 Volusia County 33. NEPTUNE LOUNGE INC PO Box 122 Atlantic Beach, FL 32233 Duval County 34. NEPTUNE LOUNGE INC PO Box 122 Neptune Beach. FL 32266 Duval County 35. NEPTUNE LOUNGE INC 10911th St Atlantic Beach, FL 32233-5751 For internal use only SDNY_GM_00059729 CONFIDENTIAL -

proceedin were already pending in a state court. Taylor Taintor, 1 Wall. 366, 370 (21 L.Ed. 28 ; e Har

ment was not made to the district court or raised in Evans's brief on appeal, and we would ordinarily deem it waived. See Saranac, LLC v. City of Neptune Beach, 410 F.36 1250. 1256 n. 6 (1 I th Cir.2005) (holding that a statutory-inter- pretation argument raised for the first time at oral argument and not

w or should have known that the claim or defense asserted was not supported by the facts or an application of then-existing law. See, e.g., Read v. Taylor , 832 So. 2d 219 (Fla. 4th DCA 2002). Epstein served another motion and letter pursuant to §57.105 on August 29, 2013, based upon the Third Distric

e 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 Counterclaim against Epstein for abuse of process and malici