Epstein Secrets

nt. I HEREBY CERTIFY that a true copy of the foregoing was furnished to all counsel on the attached service list, by email, on September 25, 2017. Jack Scarola, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 WM, BURLINGTON & ROCKENBACH, P.A. C

, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 JSX@searc

414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and other unknown part

Judgment motion that Appellant could not satisfy all of the elements of a Malicious Prosecution claim, including that the suit by Appellee against Appellant resulted in a bona-fide termination in favor of Appellant. Appellee took a voluntary dismissal without prejudice, which does not constitute a bona-

Coleman Tonja Haddad Coleman, Esq. Fla. Bar No. 0176737 315 S.E. 7th Street Suite 301 Fort Lauderdale, FL 33301 8 EFTA00808566 SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Es Atterbury, Goldberger & Weiss, P.A.

e, FL 33301 8 EFTA00808566 SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

Judgment motion that Appellant could not satisfy all of the elements of a Malicious Prosecution claim, including that the suit by Appellee against Appellant resulted in a bona-fide termination in favor of Appellant. Appellee took a voluntary dismissal without prejudice, which does not constitute a bona-

February 25, 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

able and inapposite to the instant case, and as such its narrow holding has no bearing on, and should not be considered by, this Court. Similarly, Appellant cites Wright v. Yurko, 446 So. 2d 1162 (Fla. 5th DCA 1984) in support of his assertion that the litigation privilege is inapplicable to a malicious

his assertion that the litigation privilege is inapplicable to a malicious prosecution claim. However, such reliance thereupon is misplaced. First, Appellant's characterization of Levin as impliedly approving the survival of a malicious prosecution claim in the Wright case is completely unfounded. In Levi

Dadeland Boulevard Miami, Florida 33156 Richard A. Simpson, Esquire Mary Botja, Esquire WILEY REIN LLP 1776 K Street, NW Washington, DC 20006 Jack Scarola, Esquire Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, Florida 33409 Tonja Haddad Coleman, Esq. TO

LP 1776 K Street, NW Washington, DC 20006 Jack Scarola, Esquire Searcy Denney Scarola Barnhart & Shiple

inst appellant and had the summons served upon appellant on the day he arrived at appellee's offices to participate in settlement negotiations. Id. Appellant moved to quash the service and the trial court denied the motion. The Third District, however, agreed that said service "was occasioned by fraud an

February , 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and other unknown part