Epstein Secrets

L 33301 Lilly Ann Sanchez, Esq., The L•S Law Firm Four Seasons Tower, 15th Floor, 1441 Brickell Avenue Miami, FL 33131 Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (

ng of that lawsuit. Fifth, abuse of process is based on process used for an immediate purpose other than that for which it was designed. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208 and n. I (Fla. 4th DCA 1983). Edwards, however, does not allege that any specific process was used by Epstein for an

tedly baseless lawsuit. Given the fact that the mere filing or service of a spurious claim is not itself actionable as abuse of process, see, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980), it necessarily follows that Edwa

40800XXXXMBAG Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561)

ch requires abuse of the judicial system subsequent to the filing of a complaint — not purportedly unfounded allegations in a complaint. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980). Finally, to the extent that Edw

endant/ Counter-Plaintiff BRADLEY EDWARDS' Motion For Leave to Amend to Assert Claim for Punitive Damages be denied. 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 Telephone: (

r purpose after an action was filed and process served. See,. e.g., Della-Donna v. Nova University, Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987); McMurray v. U-Haul Co, Inc., 425 So. 2d 1208, 1209-10 (Fla. 4th DCA 1983). Accordingly, the filing of an action itself does not constitute abuse of process.