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CLUSION Based on the foregoing, Edwards' Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christo
of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the pe
nts and Commentary to the Media and Press, and grant such other and further relief as is deemed necessary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 - 9 - FOWLE
e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra
nts and Commentary to the Media and Press, and grant such other and further relief as is deemed necessary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 and Christo
e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra
Entities connected to both Joseph L. Ackerman and Fla. R. Evid

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJack Scarola
PERSONScott Rothstein
PERSONJack Goldberger
PERSONFISTOS & LEHRMAN
ORGANIZATIONMarc S. Nurik
PERSON
Weissing
PERSONSouth Flagler Drive
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
Christopher E. Knight
PERSON
Prince Andrew
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSONPalm Beach Lakes Blvd
LOCATION
FOWLER
ORGANIZATIONthe Florida Rules of Civil Procedure
ORGANIZATION
Alfredo Rodriguez
PERSON