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damages. Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878, 880 (1931). The fourth element, the absence of probable cause, is at issue here. In Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956), the Supreme Court of Florida explained the meaning of probable cause in the context of a malicious prosecutio
in Cases")4 that were being used to defraud investors in the Ponzi Scheme.5 [Cite Epstein Affidavit]. News outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, S
the prosecution; 5) malice; 6) damages. Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878, 880 (1931). The fourth element is at issue here. In Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956), the Supreme Court of Florida explained the meaning of probable cause in the context of a malicious prosecuti
ns of dollars and to fund the RRA Ponzi Scheme. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware t
nt. The court rejected the Motion, calling it "devoid of evidence." (R. 833-837). The Record Demonstrates Probable Cause for Epstein's Lawsuit In Goldstein v. Sabena, 88 So. 2d 910 (Fla. 1956), the Supreme Court of Florida explained the meaning of probable cause in the context of a malicious -15- EFTA0
ons of dollars and to fund the RRA Pont Scheme. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware t
Entities connected to both Goldstein and Florida Bar

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
United States
LOCATION
Kenneth Marra
PERSONScott Rothstein
PERSON
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Alexander Acosta
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
Bill Clinton
PERSONJack Scarola
PERSON
Prince Andrew
PERSON
Virginia Giuffre
PERSON