a named Defendant herein), and two of which have been filed in state court in the 15" Judicial Circuit Court, Palm Beach County, State of Florida, (L.M. v. Epstein, Case No. 502008C A028051XXXXMB AB; E.W. v. Epstein, Case No. 502008CA028058XXXXMB AB), (hereinafter collectively referred to as the "Civil Actions," and L.