Epstein Secrets

rting.com 888 811-3408 EFTA00606577 69 62:11 forever (2) 16:12,14 forget (1) further (3) 14:19 36:7 38:10 future (1) 46:11 55:17 56:22 GOLDBERG... 2:8,10 hand (1) 36:12 handle (1) 24:24 holds (2) 25:12,16 Honor (27) 3:5 4:20,24 5:25 14:18 39:22 Goldberger's ... handled (3) 6:10,1

[email protected] 7 8 ATTERBURY, GOLDBERGER & WEISS, PA 9 250 South Australian Avenue Suite 1400 10 West Palm Beach, FL 33401 561.659.8300 11 BY: JACK A. GOLDBERGER, ESQUIRE [email protected] 12 13 TONJA HADDAD, PA 315 SE 7th Street 14 Suite 301 Fort Lauderdale, FL 33301 15 954.467.1223 BY: TONJA H

and www.phippsreporting.com 888 811-3408 EFTA00606563 55 1 shouldn't. I ruled in your favor and I've ruled 2 against you. I've ruled in Mr. Goldberger's 3 favor; I've ruled against him. I've ruled in 4 favor of Mr. Edwards' claims and contentions; I've 5 ruled against him. 6 But I'm just hav

are not subject to the litigation www.phippsreporting.com 888 811-3408 EFTA00606536 23 1 2 3 4 5 6 privilege. And if you read Wright vs. Yurko, you read Judge Cope's concurring opinion, and you read the panel's footnote in SCI, one should not come up with any other conclusion other than t

ion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 recognizes -- that is the Supreme Court itself 2

[email protected] 7 8 ATTERBURY, GOLDBERGER & WEISS, PA 9 250 South Australian Avenue Suite 1400 10 West Palm Beach, FL 33401 561.659.8300 11 BY: JACK A. GOLDBERGER, ESQUIRE [email protected] 12 13 TONJA HADDAD, PA 315 SE 7th Street 14 Suite 301 Fort Lauderdale, FL 33301 15 954.467.1223 BY: TONJA H

w.phippsreporting.com 888 811-3408 001264 EFTA00613561 55 1 shouldn't. I ruled in your favor and I've ruled 2 against you. I've ruled in Mr. Goldberger's 3 favor; I've ruled against him. I've ruled in 4 favor of Mr. Edwards' claims and contentions; I've 5 ruled against him. 6 But I'm just hav

m 888 811-3408 001278 EFTA00613575 69 62:11 forever (2) 16:12,14 forget (1) further (3) 14:19 36:7 38:10 future (1) 46:11 55:17 56:22 GOLDBERG... 2:8,10 hand (1) 36:12 handle (1) 24:24 holds (2) 25:12,16 Honor (27) 3:5 4:20,24 5:25 14:18 39:22 Goldberger's ... handled (3) 6:10,

ims are not subject to the litigation www.phippsreporting.com 888 811-3408 001237 EFTA00613534 28 1 privilege. 2 And if you read Wright vs. Yurko, you read 3 Judge Cope's concurring opinion, and you read the 4 panel's footnote in SCI, one should not come up 5 with any other conclusion oth

ion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 24 25 recognizes -- that is the Supreme Court i

, P.A. Mark Nurik Law Offices of Mark S. Nurik Jack Goldberger Atterburv. Goldberger & Weiss. P.A. -19- EFTA00

. Mark Nurik Law Offices of Mark S. Nurik Jack Goldberger Atterburv. Goldberger & Weiss. P.A. -19- EFTA00

ts known by the defendant in the malicious prosecution action at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present

at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present to the court and jury." 446 So. 2d at 1167. Here, both the aff

ida 33401 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esq. KITERBURY, GOLDBERGER & WEISS, P.A. 250

Rachel J. Glasser, Esq. LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd. Ste. 301 West Palm Beach, Florida 33401 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esq. KITERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue S., Ste. 1400 West Palm Beach FL 33401 Attorneys for Jeffrey Epstein 3 Marc S.

n determine whether Plaintiff "had a reasonable belief, based on facts and circumstances known to him, in the validity of his claim." See Wright v. Yurko, 446 So. 2d 1162, 1166 (Fla. 5th DCA 1984) (defining probable cause) (citing Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956)). Bifurcating the tria

ircuit Court Judge Copies forwarded to: Jack A. Goldberger, Esq. Counsel for the Defendant 250 Australian

s, West Palm Beach, Palm Beach County, Florida this day of July, 2008. „Ana gates EBORAH DALE PUCILLO Circuit Court Judge Copies forwarded to: Jack A. Goldberger, Esq. Counsel for the Defendant 250 Australian Avenue South, Ste. 1400 West Palm Beach, Florida 33401 Lanna Belohlavek, Esq. Assistant State Att

2 (Fla. 5th DCA 1993)). As Defendants point out, there muse be an "actionable underlying tort or wrong" for an actionable conspiracy claim. Wright, Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984). 5 EFTA00234428 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18.2008 Page 6 of 11

a state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 So. 2d 702, n.4 (Fla. 3d DCA 2002) (“As the Levin court cited Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues to exist and would not

)-745-3556 Attorneys for Scott Rothstein Jack A. Goldberger, Esquire [email protected]; Tonja Haddad Col

topher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nuri