Epstein Secrets

hese matters. He is well aware of the ramifications of his past behavior and, accordingly, there is no concem, whatsoever, that he will re-offend. FOWLER WHITE BURNETT P.A. EFTA00310834 Page 2 The following proposal is offered as an assurance to the community that the goals of appropriate punishme

to the lack of uniform regulation, these businesses have served to transfer funds which were the proceeds of illegal activity. See United States v. Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants transmitted proceeds of drug trafficking to Colombia); see also P.L. 103-325, Title IV, § 4

. 50 2009 CA 040800 XXXXMB AG Epstein's Response in Opposition to Edwards' M/Dismiss Amended Complaint Christopher E. Knight Fla. Bar. No. 607363 FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-920

law, abuse of process cannot be based solely on the filing of an allegedly groundless claim, which is the crux of Edwards' counterclaim. See, e.g., Valdes v. GAB Robins N. Am., Inc., 924 So. 2d 862, 867 (Fla. 3d DCA 2006)("Valdes' failure to allege any improper willful acts by the appellees during the

v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4'h DCA 1983)(same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980)("[N]o abuse of the - 4 - FOWLER WHITE BURNER P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14" FLOOR, MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA00584351 Epstein v. Rothstein

ss.' [Citation omitted] The plaintiff must prove improper use of process after it issues." S&I !mu., 36 So. 3d at 917 (quotation omitted). See also Valdes, 924 So. 2d at 867 ("Valdes' failure to allege any improper willful acts by the appellees during the course of the prior action requires dismissal