This protection also arises in part because lawsuits brought by public figures such as Bradley Edwards which seek compensation and punitive damages for harm to reputation are regarded as infringing on free speech rights See New York Times Co Sullivan U.S Silvester American Broadcasting Cos Inc F.2d 11th Cir The protection requires that Edwards prove with convincing clarity that Epstein filed and prosecuted his lawsuit against Edwards with knowledge of the falsity of the claims advanced or reckless disregard for the truth of those claims See also McDonald Smith U.S holding Petition Clause would not bar libel claim arising from petitioning activity if plaintiff met requirements of New York Times Co Sullivan In addition Epsteins lawsuit against Edwards made claims that Edwards has abused the process of this Court in order to defraud persons and entities to financially support the prosecution of litigation Speech of this nature is a matter of public concern Accordingly the First and Fourteenth Amendments of the U.S Constitution as well as Article I Section of the Florida Constitution prohibit the imposition of liability against Epstein absent proof of fault and also prohibit the award of presumed or punitive damages absent clear and convincing evidence of knowledge of falsity or reckless disregard for the truth Gertz Robert Welch Inc U.S Edwards claims also are nothing more than defamation claims which are barred by defenses applicable to defamation claims A plaintiff may not avoid defenses that apply to defamation actions by characterizing them as torts that are not subject to those restrictions Callaway Land Cattle Co Banyan Lakes Corp So 2d Fla 4th DCA see also Tobinickv Novella No WL at S.D Fla Jan Hillv Allianz Life Ins Co ofN Am Eyeglasses No WL M.D Fla Feb Klayman Judicial Watch Inc Supp 3d S.D Fla affd No 11th Cir Feb Ortego Trujillo Banco Central Del Ecuador Supp 2d S.D Fla Fridovich Fridovich So 2d Fla Ovadia Bloom So 2d Fla 3d DCA Orlando Sports Stadium Inc Sentinel Star Co So 2d Fla 4th DCA Clarkv Clark No WL Fla 4th Cir June The proposed amendment clearly sets forth this principle as a defense to Edwards Counterclaim Finally the proposed amendments to the affirmative defenses sets forth that the Due Process Clauses of the U.S and Florida Constitutions restrict the awarding of punitive damages and that statutory and common law procedures for awarding of punitive damages are inadequate to secure Due Process to Epstein THE RULES REQUIRE THAT THE AMENDMENTS BE ALLOWED Rule a governs amendments to pleadings and provides in relevant part that leave of court shall be given freely when justice so requires Justice requires the amendment because if properly established the additional affirmative defenses provide an absolute defense to all of the causes of action asserted by Edwards See Royal Trust Bank N.A Von Zam.ft So 2d Fla 3d DCA Consequently Epstein should be permitted to amend his pleadings The proposed amendment does not change Epsteins answer to the allegations of the Fourth Amended Counterclaim Rather it simply adds Affirmative Defenses which arise from the facts that Edwards was a public figure at the time that Epstein filed his Complaint against Edwards and at all times thereafter the subject matter of the lawsuit on which Edwards filed his claims is a matter of public concern Epsteins Complaint is a form of petitioning the government and Edwards lawsuit seeks no relief other than for supposed harm arising from the publication of defamatory statements and therefore it is subject to all defenses that are applicable to claims for libel or slander Assertion of the additional defenses will cause no prejudice to Edwards because Edwards has been aware of all of these facts from the outset of this litigation No discovery is needed to test the veracity of the facts The lack of prejudice to Edwards requires allowance of the proposed amendment New River Yachting Center Inc Bacchiocchi So 2d Fla th DCA Leave to amend should not be denied unless the privilege has been abused or the pleading is clearly not amendable Osborne Delta Maintenance Welding Inc So 2d Fla 2d DCA This determination should be governed by a policy favoring resolution of cases on their merits unless the privilege of amendment has been abused Enstrom Dixon So 2d Fla th DCA holding that it is the policy in this State to freely allow amendments to pleadings in order that causes may be tried on their merits and justice may be achieved In exercising the discretion inherent in the trial court to allow or disallow amendments all doubts should be resolved in favor of the former unless the privilege is abused Epstein has not abused his right to amend Indeed he has not amended his Answer and Affirmative Defenses to the Fourth Amended Counterclaim at all Moreover as is clear from the Fourth Amended Counterclaim Edwards status as a public figure and the fact that the lawsuit filed by Epstein against Edwards involves a matter of public concern will be in evidence at trial inasmuch as those facts are essential to Edwards claims Rule expressly provides that amendment of the pleadings shall be allowed to conform to the evidence CONCLUSION WHEREFORE Plaintiff moves this Court to permit the filing of the proposed Amended Answer and Affirmative Defenses to Edwards Fourth Amended Counterclaim a copy of which is attached as Exhibit A DATED November Respectfully submitted LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Farmer Jaffee Weissing Edwards Fistos Law Offices of Marc Nurik Lehrman One Broward Boulevard Suite Andrews Avenue Suite Ft Lauderdale FL Fort Lauderdale FL marc nuriklaw.com staff.efile gathotojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonj a tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Chester Brewer Jr Jack A Goldberger Chester Brewer Jr P.A Atterbury Goldberger Weiss P.A Australian A venue Suite Australian A venue Suite West Palm Beach FL West Palm Beach FL wcblaw aol.com goldberger agm:,a.com wcblawasst gmail.com smahoney agwa.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs EXHIBIT A I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEINS FIRST AMENDED ANSWER AND AFFIRMATIVE DEFENSES TO THE FOURTH AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein Epstein pursuant to Rule of the Florida Rules of Civil Procedure files his Answer and Affirmative Defenses to Defendant/Counter-Plaintiff Bradley Edwards Edwards Fourth Amended Counterclaim Counterclaim and states Epstein admits that the Counterclaim alleges an amount within the jurisdictional purview of the Court but denies that Edwards is entitled to said amount Epstein is without knowledge as to Edwards residential status but admits that he is an attorney licensed to practice law in the State of Florida Epstein admits that he is suijuris but denies he is a resident of Palm Beach County Florida Epstein admits that he entered into a plea agreement that resulted in a felony conviction Epstein further admits that the terms and conditions of the agreement speak for themselves To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that he was a party to civil actions brought forth by purported victims but is without knowledge as to any further investigation by federal law enforcement or Edwards relationship with any other purported victims and therefore denies these allegations and demands strict proof thereof Epstein admits that during certain times throughout the litigation he asserted his rights against self-incrimination as afforded him by the Fifth Amendment to the United States Constitution Epstein denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies Paragraph exception for the allegation therein stating that Edwards is involved in pending litigation in Federal Court under the Federal Crime Victims Rights Act Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein admits some of the causes of action filed by him against Edwards are delineated in Paragraph and its subparts To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that in one of his Complaints he alleged some of the causes of action against Edwards as specifically stated in paragraph and its subparts but denies that he has ever asserted a cause of action for Civil Theft against Edwards as alleged in Paragraph To the extent that Edwards has inaccurately summarized or interpreted any provision of Epsteins Complaint in Paragraph of his Counterclaim,2 Epstein denies the allegations Epstein further denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and its subparts and demands strict proof thereof With respect to subsection of Paragraph Epstein further denies that Edwards actions were afforded absolute protection under the litigation privilege See Delmonico Traynor So 3d Fla Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Edwards fails to attach a copy of Epsteins Complaint or even reference the version of the Complaint to which he refers in this allegation Edwards fails to attach a copy of Epsteins Complaint or even reference the version of the Complaint to which he refers in this allegation Epstein denies each and every allegation and claims for damages that is contained in Paragraph including its subparts and demands strict proof thereof Epstein admits that the Counterclaim alleges an amount within the jurisdictional purview of the Court but denies that Edwards is entitled to said amount Epstein is without knowledge as to Edwards residential status but admits that he is an attorney licensed to practice law in the State of Florida Epstein admits that he is sui Juris but denies he is a resident of Palm Beach County Florida Epstein admits that he entered into a plea agreement that resulted in a felony conviction Epstein further admits that the terms and conditions of the agreement speak for themselves To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that he was a party to civil actions brought forth by purported victims but is without knowledge as to any further investigation by federal law enforcement or Edwards relationship with any other purported victims and therefore denies these allegations and demands strict proof thereof Epstein admits that during certain times throughout the litigation he asserted his rights against self-incrimination as afforded him by the Fifth Amendment to the United States Constitution Epstein denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein admits some of the claims initially filed by him against Edwards are delineated in Paragraph and its subparts To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that in one of his Complaints he alleged some of the causes of action against Edwards as specifically stated in Paragraph and its subparts but denies that he has ever asserted a cause of action for Civil Theft against Edwards as alleged in Paragraph To the extent that Edwards has inaccurately summarized or interpreted any provision of Epsteins Complaint in Paragraph of his Counterclaim Epstein denies the allegations Epstein further denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and its subparts and demands strict proof thereof With respect to subsection of Paragraph Epstein further denies that Edwards actions were afforded absolute protection under the litigation privilege See Delmonico Traynor So 3d Fla Edwards fails to either attach the Complaint to his Counterclaim or reference the specific Complaint to which he is referring in Paragraph Edwards fails to either attach the Complaint to his Counterclaim or reference the specific Complaint to which he is referring in Paragraph Epstein denies each and every allegation in paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein admits that he amended his Complaint over the course of the litigation and that some counts contained in his Complaint were dismissed by the Court without prejudice However Epstein denies that this constitutes abandonment of his claims and/or a bona fide termination of his claims in Edwards favor Epstein denies any and all remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation and claim for damages that is contained in Paragraph including its subparts and demands strict proof thereof Epstein denies Edwards is entitled to any demand made in his WHEREFORE clause including any assertion of alleged Punitive Damages AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE For his First Affirmative Defense Epstein states that Edwards Abuse of Process claim fails to state a claim upon which relief can be granted as required under Rule of the Florida Rules of Civil Procedure Edwards did not nor will he ever be able to assert the three requisites required to properly plead same to wit an illegal improper or perverted use of process after it issues an ulterior motive or purpose in exercising the illegal improper or perverted process and damages resulting therefrom I Invs Payless Flea Mkt Inc So 3d Fla 4th DCA Della-Donna Nova Univ Inc So 2d Fla th DCA SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense Epstein states that Edwards Malicious Prosecution claim fails to state a claim upon which relief can be granted as is required under Rule of the Florida Rules of Civil Procedure Specifically the requisite of a bona fide termination of the original proceeding in favor of the present plaintiff as delineated by the Florida Supreme Court as one of the legally-mandated elements to bring forth a malicious prosecution claim has not nor can it be satisfied See Alamo Rent-A-Car Mancusi So 2d Fla The original proceeding to which Edwards refers in his Counterclaim is in fact the case Epstein voluntarily dismissed without prejudice and could refile at any time A bona fide termination would prohibit re-filing As such there has not been the required ending in a manner indicating Edwards innocence of the charges or allegations contained in the first suit See Doss Bank of Am N.A So 2d Fla th DCA See also Yoder Adriatico So 2d Fla th DCA stating that the tort of malicious prosecution may not be brought as a counterclaim Indeed it is well-settled law that an action for malicious prosecution cannot be filed until the original action is concluded and that counts of a Complaint that are dismissed without prejudice are not deemed a bona fide termination in the partys favor Where dismissal is on technical grounds for procedural reasons or any other reason not consistent with the guilt of the accused it does not constitute a favorable determination Union Oil of Cal Watson So 2d Fla 3d DCA Accordingly Edwards fails to state a claim upon which relief may be granted THIRD AFFIRMATIVE DEFENSE For his Third Affirmative Defense Epstein states that Edwards Counterclaim fails to properly plead his damages as required under the Florida Rules of Civil Procedure See Miami Nat Bank Nunez So 2d Fla 3d DCA stating that a litigant cannot recover as damages his own time for participating in a litigation when counsel is engaged to represent him Edwards further pleads damages for injury to his reputation mental anguish anxiety and embarrassment which are impermissible and improperly plead Finally Edwards fails to properly plead punitive damages as required by the Florida Rules of Civil Procedure More importantly however Epstein states that Edwards has not nor will he suffer any damages as a result of any actions allegedly taken by Epstein In fact this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein Rosenfeldt Adler Moreover Edwards still utilizes his litigious association with Epstein at his new firm Farmer Jaffe Weissing Edwards Fistis Lehrman both on its firm website and firm Facebook page to disparage Epstein to seek new clients on whose behalf he can sue Epstein to attract plaintiffs for whom he can file suit and to achieve notoriety with the press See Composite Exhibit A attached hereto FOURTH AFFIRMATIVE DEFENSE For his Fourth Affirmative Defense Epstein asserts that he is afforded absolute immunity pursuant to the Litigation Privilege because his actions were connected with relevant to and material to the cause at hand The Litigation Privilege protects actions taken that are related to the judicial proceeding Litigation Privilege arises immediately upon the doing of any act required or permitted by law in the due course of the judicial proceedings or as necessarily preliminary thereto Fridovich Fridovich So 2d Fla This absolute immunity afforded to Epstein pursuant to the Litigation Privilege appears on the face of the Counterclaim as filed by Edwards As such Edwards is barred from proceeding with the litigation FIFTH AFFIRMATIVE DEFENSE For his Fifth Affirmative Defense Epstein asserts that his lawsuit against Edwards upon which Edwards claims are based is a form of petitioning government for redress Accordingly Edwards claims are barred by the First and Fourteenth Amendments of the United States Constitution unless Edwards can show that Epsteins lawsuit was a sham as that term is used in the Noerr-Pennington doctrine See United Mine Workers of Am Pennington U.S Eastern R.R Presidents Conference Noerr Motor Freight Inc U.S A lawsuit is regarded as a sham only if the lawsuit was objectively baseless in the sense that no reasonable litigant could realistically expect success on the merits and the lawsuit conceals an attempt to interfere directly with the business of the subject of the suit In addition Edwards claims are barred by Article I Aection of the Florida Constitution and the common law protection that Florida law provides to the filing oflawsuits unless Edwards can prove that Epsteins primary motivation for filing his lawsuit against Edwards was to inflict injury on Edwards and that Epstein used his privilege to sue Edwards to gratify feelings of malevolence toward Edwards Fridovich Fridovich So 2d Fla Nodar Galbreath So 2d Fla SIXTH AFFIRMATIVE DEFENSE For his Sixth Affirmative Defense Epstein asserts that Edwards at the time that Epstein sued Edwards and all times thereafter was a general or limited-purpose public figure who may not in accordance with the First and Fourteenth Amendments of the United States Constitution and Article I Section of the Florida Constitution prevail on his claims in the absence of clear and convincing evidence that Epstein knew of the falsity of the claims that he made against Edwards or recklessly disregarded the falsity of those claims See New York Times Co Sullivan US Silvester Am Broadcasting Cos Inc 2d 11th Cir See also McDonald Smith U.S holding Petition Clause would not bar libel claim arising from petitioning activity if plaintiff met requirements of New York Times Co Sullivan Edwards has no such evidence and therefore his claims fail SEVENTH AFFIRMATIVE DEFENSE For his Seventh Affirmative Defense Epstein asserts that the lawsuit filed by Epstein against Edwards upon which Edwards claims are based involves a matter of public concern Accordingly Edwards whether a public figure or not may not in accordance with the First and Fourteenth Amendments of the United States Constitution and Article I Section of the Florida Constitution prevail on his claims in the absence of evidence that Epstein was negligent in failing to discover the falsity of the claims that he made against Edwards Gertz Robert Welch Inc U.S Edwards has no such evidence and therefore his claims fail In addition Edwards may not in accordance with the First and Fourteenth Amendments of the United States Constitution and Article I Section of the Florida Constitution recover presumed or punitive damages without clear and convincing evidence that Epstein knew of the falsity of the claims that he made against Edwards or recklessly disregarded the falsity of those claims EIGHTH AFFIRMATIVE DEFENSE For his Eight Affirmative Defense Epstein asserts that Edwards claims are nothing more than defamation claims which are barred by defenses applicable to defamation claims as set forth in the defenses above A plaintiff may not avoid defenses that apply to defamation actions by characterizing them as torts which are not subject to those restrictions Callaway Land Cattle Co Inc Banyan Lakes Corp So 2d Fla 4th DCA see also Tobinick Novella No WL at S.D Fla Jan Hill Allianz Life Ins Co ofN Am Eyeglasses No WL M.D Fla Feb Klayman Judicial Watch Inc Supp 3d S.D affd No 11th Cir Feb Ortega Trujillo Banco Central Del Ecuador Supp 2d S.D Fla Fridovich Fridovich So 2d Fla Ovadia Bloom So 2d Fla 3d DCA Orlando Sports Stadium Inc Sentinel Star Co So 2d Fla 4th DCA Clark Clark No WL Fla 4th Cir NINTH AFFIRMATIVE DEFENSE For his Ninth Affirmative Defense Epstein asserts that the Fifth and Fourteenth Amendments of the United States Constitution and Article I Section of the Florida Constitution guarantee Due Process of law The Florida common law and statutory principles that govern the awarding of punitive damages are not sufficient to assure Epstein Due Process of law They do not adequately restrain the discretion of the jury they do not ensure that the decision with respect to punitive damages will be made by the appropriate authority they do not restrict punitive damages so that they are not disproportionate to the harm that was caused by the actions of Epstein and they do not ensure that Epstein is protected from duplicative punishment for any acts in which he is found to have engaged Epstein specifically reserves his right to amend these defenses and plead other affirmative defenses that may become known during his continuing investigation of this action and during discovery in this case DATED November Respectfully submitted LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL sx searcylaw.com njs FLAAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Farmer Jaffee Weissing Edwards Fistos Law Offices of Marc Nurik Lehrman One Broward Boulevard Suite Andrews A venue Suite Ft Lauderdale FL Fort Lauderdale FL marc nuriklaw.com staff.efile pathotojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonja tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Chester Brewer Jr Jack A Goldberger Chester Brewer Jr P.A Atterbury Goldberger Weiss P.A Australian Avenue Suite Australian Avenue Suite West Palm Beach FL West Palm Beach FL wcblaw aol.com goldberger agwpa.com wcblawasst gmail.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein COMPOSITE EXHIBIT A una Announcements 267Farmer J.affe Weissin_g Edwards Fistos Lehrman Pi 267oven Results Media Blog Page:l of14 search Soarch September Attorney Brad Edwards who is representing several young men who.say former youth pastor xually abused:and physically abused them was interview_ ed by CBS4 MIAMI Firm Supports RAINNDAY September 27th Farmer Jaffe Weissing Is proud to support Rape Abus Incest National Networks RAINN Day September 27th RAINN Day Is RAINf Js annual campaign to raise awareness and educate students against sexual violence on college campuses RAINN DAY is a grassroots program designed to empoweicollege students toraise awareness of sexual violence and recovery resources on their campus Click here to learn how farmer Jaffe Weissing helps crime victims and victims of sexual assault I UIU lJUflCCiUCUlS Page of Attorney Steve Jaffe Interviewed in Elder Abuse Case Naples News interviews_ attorney Steven Jaffe regarding his case involving elder abuse A care facility took 267control of an ailing dementia patients trust accqunt ys_ before her death with the assistance ofa Fort Myers attorney The case which was filed in still pending Zambrano Named to Million.Dollar and Multi-Million Dollar Advocates Forum Attorney Gabriel Zambrano has been certified as amemberofboththeMillion Dollar Advocates Forum and the Multi-Million Dollar Advocates Forum Fewer than of U.S lawyers are members Forum membership acknowledges excellence in advocacy and provides members with anaticmal network of experienced colleagues 267for professionalreferrat 267and information exchange in major cases Members of.the Multi-Million Dollar Advocates Forum must be Life Members of the Millio_n Dollar Advocates Forum and must have acted as principal counsel.In at least one case which has resulted in a inulU million dollar verdict award or settlement October JY Farmer FJA President Presents Civil Justice Merit Retention to FAMU Law Students FJA President Gary Farmer meets with Florida Agricultural and Mech_a ical University FAMU law students to discuss thedvil justice system and view the documentary Hot Coffee Here Gary shows his appreciation to the FAMU Law School Aml a sat:lors for the.Florida Justice Association FJA A esidentG_a Fanner Addresses Law Students oil Merit Retention Judrcral System Page of Florida JListice As ociation President Gary Farmer spoke to more than law students at the Coastal Law School Outreach Reception about the importance of Justice and Merit Retention nd why it matters 267students also watched a showing of Hot Coffeet the documentary film thatanalyzes and discusses the impact of tort reform on tile United.States judicial system Four other colleges and universities will be partlcipaU11g in similar discussions ovefthe next couple of weel Firm Attorneys Attend Present at MTMP eminar Several of the firms attorneys are attending the Mass Torts Made Perfect Seminar this week October Attomeys Garv Farmer and Matt Weissing presented Qui Tam Blowing the Whistle on Corporate Fraud at the Securities and Business Torts Breakout session of the MassTorts Made Perfect Seminar on October 12th Class Action Final Approval Gra11ted We obtained final approval of a Class Action case against Continental Casualty Company CNA for systematic denial oflong term care insurance claims Were very pleased to recover meaningful insurance benefits for a deserving group of Floridians and we are equally pleased.to protectthe status of nurse registries as 267covered providers 225CCllter/prcss-relcnses uvlim;c1ncnts Pagc4 of FJA Founders Awards Dinner Ga Zambrano Gary Farmer FJA President and 267eth Lehrman attended the Florida Justice.Associations FJA Fo naers Awards Dinner in Boca Raton on October 1h Gary Fanner Sr Addresses,FloridaSupreine CourtJustices Attorney Gary Farmer Sr argued before Florida Supreme G9urt.yesterday on_ behalfoftheRespondentregarding an uninsured motorist insurance policy claim Supports National Crime PrewentionMonth Farmer Jaffe Weissing proudly supports Na ion_al Crime Prevention Month October sponsored by the National Crime Prevention Council NCPC National Crime Prevention Month recognizes and celebrates the practi9e of crime prevention while promoting awarel ess of important issues such as victimization volunteerism and creating safer more caring communities.This year the firm wants to raise help awareness of the following crimes sexual abuse assault negligent security and inadequate security and nursing home abuse and neglect safety Issues.Visit our Face book Google and Twitter feeds for ways to protect you and your family http://w;patht Page Sofl4 t!f WC1i ro aJLl Here you will find our breaking news and nnq4.ncements from our firm We welcome any 1ngu1nes If you have any questions regarding a release or case please contact us For Archived ress Release chck here AQ 267gust Jury Aw rds Million t9 Woman Injured in Plummeting levator.Ac 267c1dent PartnerBrad Edwards received a million verdict onAugust Brad Edwards:31 following a twoweek jury trial Thirteen years ago Ja_nice Beasley years old was riding in ah elevator that plunged several floors before 267crashing to an abrupt stop Ms Beasley sustai11eq significant permanent injuries which have confined her to awheelchair for nearly 13.years The d_ere 267ndalits sought.to avoid responsibiilty for this accident which Ms Beasley believed was both preventable and the cause of more than a decade.of life changing medical problems Five Farmer-Jaffe Veissing Attorneys Included in The-Best Lawyers 1n Amersca The firm is pleased to announce that five of the firm attorneys have been selected by t11eif peers for inclusion in The Best Lawyers in Americ Copyrigh by Woo_dward/White Inc ofAiken SC The following attorneys were selected 1n their respective pratie areas Gary Farmer Jr Mass Torts Litigation Class Action Plaintiffs Steven Jaffe Mass Torts Litigation Class Action Plaintiffs Matt Weissing PersonaUrijury Litigation Plaintiffs Brad Edwards Personal Injury Litigation Plaintiffs Gary Farmer Sr Appellate Practice ccntcr/prcss:;rcleascs iuiuuncements Page.6 of i _?nsors ABOTA AnntJal Professionalism he American Bo 267ard of Trial Aavocates ABOTA Fort Lauderdale Chapter held its 1st Annual Professionalism Program in honor of Henry Latimer Farmer Jaffe Weissing was one of several sponsors.where members of the Judiciary their Judicial Assistants and locc:1I members of the Bar explored Issues facing the profession from the prospective ofthese groups For photos of the event visit ABOTAs Facebook Page Justi for Amp_utee in Plane Propeller Accident The attorneys and 267staff at Farnier Jaffe Weissiilg are proud to have been able to assist out client Mr Evans whose arrn had to be rnplltatecfas a result of an airplane propeller accident in his pursuit of justice and fair compensation and to hold Greenwich Insurance Co to its obligations This case higt1Hghts the in.,portance of obtaining insurance coverage to account for the possibility that an injury could occur on ones premise and how too 267often insurance companies disregard their contractual obligations and leave prudent businesses exposed to potentially devastating judgments Floridians at the Mercy of Private Insurance Companies Read Gary Farmer Jrs important editorial on State Farms recentrequestfor a insurance rate increase Why does State Farm Insurance Co seek a"statewide average Increase The simpE and sad answer Because it can So whatshould homeowners and renter do Ask for addition.al pub lie i hearing regarding the renters insura.nce and an other Insurance rate increases And tell the Office of Insurance Regulation reject State Farms unreasonable price.hikes Click here to read complete edit ral For theTallahassee Democrat Cilek here A Torch That Burns For _Justice Meet the current Florida Justice Association President Gary Farmer Jr In the case of th_e Farmer family the torch has been ssed Click here to view entire article II Ii uiuUllflCCmcnts Page ofl4 Firm Cases Re.cognized as Top Florida Verdicts Settlements for Firm Attorneys MattWeissing Brad Edwards and Gabriel Zambranos cases were recently published i the Daily Business Review and VerdictSearch.coms Top Florida Verdicts and Settlemeiltsfor Matt Weiss Ing and Brad Edward;s premises liability case was againstFestival Fun Parks L.Lc Doing BusinessasBoomers A young rnan 225with:a promising football career was shot in the rking lot and sustained permanent nerve injury due to the propertys lack of security FoUowing a two.:week trial a Broward County jury returned a verdict in favor of the plaintiff for Gabriel Zambrano and co counsels product liability case was against R.J Reynolds.Tobacco Company and Phillip Morris.They represented a widow whose husband was a smoker The case alleged that the cigarettes caused the mans fatal.lunch cancer A jury.returned a 267verdict in favor of the plaintiff for Clas.s ction Case Against CNA Receives Prehm1nary Approvar Our clients class action case againstCNA for AttorneysSteven Jaffe and Mark Fistosdiscrimlnation against Nurse Registries in FL has received preliminary approval from Federal Judge Zlock Farmer Jaffe Weissing attorneys Steven Jaffe and Mark Fistos were named Class Counsel Final apprqval hearing is set for September 27tli have total confidence that Judge.Zlock will entera finalorder at the.September hearing thus ending the discriminatory practices of CNA said Jaffe Nwse Registries around the state should be very happy relcascs u11u A:1mounccments Page of Gabriel Zambrano Joins Farmer Jaffe Weisslng We are pleased to announce that trial attorney GabrielF Zambrano has joiried the Farmer Jaffe Weissing team Zambranos practice will focus onmass torts defective drugs defective medicarproducts personal Injury and wrongful death litigation Zambrano gained nationaflirciminence as ah E3arly advocate on behalf i of girls and women that suffered life altering blood clots strokes or heart damage from use of the DROSPIRENONE DRSP containing birth control pHls trademarked and manufactured by BAYER.HEALTHCARE PHARMACEUTICALS YASMIN YAZ BEYAZ SAFYRAL.He is currently accepting and investigating cases involving PRA AXA DABIGATRAN Page of officially sworn in as the 53rd President during the Florida Justice Associations Anmml Conv ntlon helcto11Friday June at the Marriott Beach Resort Golf Club Spa on Marco Island Jud_ge Grants Final Approval in David Stern Class Action U;S District Judge Robert Scola Jr entered an order on June a granting final apprqval of the class action law suit ir volving fqreclosure attorney David Stern for violations of federal labor laws by him former employees Attorneys Steven Jaffe Gary Farmer Jr Mark Fistos,.alld Seth Lehrman along with co-counsel Dawn Rapoport and Chandra Parker Doucette represent.ed a cla of hundreds oformer employees of the Law.Offices of Davld:Stern P.A DJSP Enterprises Inc and Sterns a.ffiliatea fpreclosure processing businesses Rea Gc!ry Farmers Legislation Session Review 1n the SFLG Attorney Gary Farmer Jr takes a look back at the Legislative Session in ttle 267South Florida Legal Guide Farmefls c1active Florida Justice Association lobbyist who has spentmorethan six i.-Veek each year for the past seven working only on consumer protections and access.to the courts Farmer Speaks to Students at Local School Attorney Garv Farmer,,Jr spoke to students at Heron Heights Gary FarmerElementary SchooUn Parkland Florida on June 1st ti the importance of the BUI of Rights MAY Edwards Included in The National Trial Lawyers Associations Top Under Attorney Brad Edwards has been included as a memberofThe Natio al Trial Lawyers Associations Top Under This invitation 1s extended exclusively to those individuals who exemplify superior qualifications trial results and leadership as a young lawyer under tlie age of Jaffe Presents at Private Care Associations BestPractices Conference Attorney Steve Jaffe presented Current Litigation Trends When D?a lng With Denials on LongTerm.lnsurance at the 225Private Care Assoc1atron of Flt ridas Best Practices Conferences for gistries in Fort Lauderdale l1ttp VWW;pathtojusti I u1uu11 s;mems APRIL Crolm Colitis Fundralser-4th Largest Ever Attor ey Steve 267Jaffe_thanks everyone who ff 1ri1/i rmZJ donated and Team Lyndsay Take Steps lrli Be Heard Crohns Colitiswalked for Team ii Elt Lindsay in the Take Steps for Crohns ilit fil c_oHtis on Saturday April at Arts Park on Young Circle in Hollywood Team Lindsay helped raise more than which helps support patient programs education and furthers crucial researchi The entire even raise over the 4th largest fundraiser Brad Edwards Runs for Victi11fs Rights un To Remembe 5KAttorney Brad Edwards participated in the Broward Victims Rights Coalitions Annual Run toRemember 5Kin Hollywood on April The event raised awareness and funds to benefit crime victims in Broward County Bra_d Edwards Presents Seminar on Enforcing VictimsRights Attorney Brad Edwards ah ave Training Cohsultanti pr sentecf an 8-hour seminar on Enforcing Victims Rights as part of the Palm Beach Victims Rights Coalitions Extending the Vision Reaching Every Victim Program on April in West Palm Beach The seminar which was part of a week long series of progrc1rhs by th PalmBeach Victims 267Right Coalition was also rt of National Crime Victims Rights Week April Brad_Edwards Presents Webinar on Maximi:zingRecovery for Sexual Abuse Victims Attorriey Brad Edwards presenteq an important online webinar on April on Maximizing Recovery for Sexual Abuse Victims as part of SeminarWeb Live FJA Webinar This presentation was part of National QrirneVictims Rights Week Gary Faimer Presents at Auto Insurance Seminar Attorney Gary Farmer Jr presented Constitutional lssu Arising Under New PIP at the Florida Justice Associations Auto Insurance Seminar in Orlando on April Gary Farmer Presents at National Tria/Lawyers Associaton Conference Attorney Gary Farmeri Jr presented State Attorney Genera Gary FannerActions iri Drug Cases Are You Wasting,AII of Your Hard Work at the National Trial Page tr ofl4 awyers Associa,Uoiis Mass_ Tort Made Perfect Conference in Las Vegas on.April Gary Farmer1Sr Presents at National TrialLawyers Association Conference Gary Farmer Sr was partof a panel that discussed The Gary Far:1_:r Effects of the Precedent:.setting Mensing Kendall Dec1s1ons at the National Trial Lawyers Associations Mass Tort Made Perfect Conference in Las Vegas on April Farmer Jaffe Weissing Support National Crime Victims Rights Week Farmer Jaffe Weissing Edwards Fistos Lehrman proudly support National Crime Victims Rights Week-April sponsored by the U.S Department of Jtistice Office for Victims of Crime OVC To learn about how vJe help crime yictims visit w.pathtoiustice.com w.Iusticetovictims.com or w.abuseandassault.com oVC FarmerJaffe WeissingArJvocates Natit;malSexual AssaultAwareness Month Farmer Jqffe Weissing Edwards Fistos Lehrman,Sexual Assault Awareness MOnth SAAM April sponsored by the the National Sexual Violence Resource Center NSVRC View Release SeAual Assault Awareness Month MARCH Brad Edwards Presents at Florida Justice.Associations Workhorse Seminar Attorney Brad Edwards presented Maximizing Recovery for Brad Edwards Sexual Abuse Victim asp 267artof the Florida Justice Associations Workhorse Seminar on March in Or_lando Brad devotes a large amount of his practice to sexual abuse and sexual assault cases He is a major advocate for victims rights and has provided hundreds of hoUrs of probono services each year to Victims Advocates Services and victims rights groups throughout Florida GaryFarmei Pr sents at Florida Justice 267Associatians WorkhorseSemin_ar http:/i auav.:1cc::1ncnrs AttcJrney Gary Farmer Jr p_resente.d Gary FarmerEverything You _Always_Wanted.To KnowAb_outQui Tam Cases 267sut were Afra1 lo Ask at the.Florida Justice Associations Workhorse Seminar on March in Orlando Gary Farmer 4th DCJ:J Ruling Quoted in The Atlantic Magazine Regardmg the Trayvon MartinShobting 267Gary Farmer_ Sr.s 4th DCA Opinion was quoted in The Atlantic regarding the Tray on artr shooting Heres ho oheFlorida appellate judge in a ruling interpreted the low legal threshold necessary to move lft the burden of proof on self-defenseJrom people like Zimmerman to prosecutors To repeat the law did not require 267defendant to 267prove.hls justi cation of self defenseto any standard measuring an assurance of truth He did not have to prove the exigency of elf-:defemse to a near certainty reasonable ci6ubt or even to a mere probability greatenvelght His only burden was to offer additional facts from which it could be true that his resort to such force could have been reasonable emphasis_ in originalt Click this link to read Mr Farmers ruling Sllpp_ort Team Lindsay Crohns Colitis Take Steps Wallt Once againSteffi ndl Steve Jaffe have formed Team Lyndsay Take Steps Be Heard Crohns ColitisTeam Lindsay towalk.hi oi.tr annual Take Steps Walk on Sa.turday A __ pril This y.ear.the w_ al will _be 267held in.A il i ffslt fil NEW LOCATION at ArtsPark on Young Circle Ill tdi ili!e tl;1 Hollywood Lclst yeaf.s event drew more tha11 people Wi:1 nlili1fil and raised over This years event promises to be a fun filled eyening for the enUre family As you all know our daughter Lindsay was diagnosed with Crohns disease when she was years old She has done remarkably well for herself despite the flair ups and hospitalizations thal.she has endure cl over the years She became an accomplished.scholarship athiete 267playlng soccer atAppalachian StateUniversity She has graduated and is pursuing a career in Sports Administration We are so proud ofher Unfortunately others a not fared.as wellas Lindsay arly rnillion An ricans rptJny who a.re children s_uffer from Crohns and Colitis and the number of people being diagnosed each year is Increasing The funds We ral through Tetke Steps Walk will help 247Upportworld class scientific research and sponsor educational programs and services for those afflicted with these diseases our ha 260peisthat otherswi/1 be able.to manage the disease aswell as Lindsay has so far http W.pathfojusticc.C itt/rncd_in-ccnter/prcss releases h,lUUOCClClltS Page of w_e wm!ld real appreciate your support Please visit Team Lindsay page Just on this nk an sign up to be a team member on Team Lindsay It will be a fun rnght There will be plenty of food and entertainment if you are unable to attend the walk any donation is,greatly appreciated Firm Hosts Press Con.ference far Attorney RepresentingTrayvon Martins Benjamin Cru1np Gary Farmerbur firm hosted a press conference today for Attorney Benjamin Crump of Parks and Crump in Tallahassee who is representing Trayvon Martins family the young teenager shot and killed bywatch captain George Zimmerman Here Attorney Crump talks to Attorney Garv Farmer Jr before the news conference Formore photos of the nevvs conference click here Former Employees.of David Stern Agree to 267settlement Approximately former employees of foreclosure attC:nheyDaVid Stern who alleged that Stern and DJSP Enterprise d.id tgive them days notice as required by the Federal Worker Adjustment and Retraining Notification or WARN Act have reached a preliminary settlement Our firm and co-counsel Dawn Rapoport ancJ Chandra Parker Doucette representthe named plaintiffs and class members A final hearing before U.S District Judge Ursula Ungaro will be held in Mi rni In June Media coverage includes the Sun-Sentinel and the Daily Business Review Seth Lehrman Guest Lectures at Nova Sautheasterrf University Law School Attorney Seth Lehrman was a guest lecturer at Nova Southeastern Universitys Law School Seth presented onprofessional responsibility and ethics His lecture focused on protecting clients 267rlghtsfollowing the dissolution ofa law firm Attorrn Seth I Lehrm Fanner Jaffe Weissing Edwards Fistos All rights reserved.Sltemap Legal Discl:.-1iln1 Your Path to Justice Begins and Ends With Us Home About Us Practice Areas Attorneys Proven Results Blog Contact Lis Path To Justice FARMER JAFFE,WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale hltp://w pathtoj Page of __ Uuse.W1tnesses I F.armerJaffe Weissing Farmer Jaffe Weissing Edwards fistos a Lehrman P.L CALL TODAY FOR A Free CA.SE EVAI UATIQN 267search llt1mc SlXtral husc ScnUls lrnrch a i Ships a I Iv Ire Disahkd Persons EnlL 267r1aii n11.mi lmluslrv rli Exd1at1!!1 225nstcr arL kdical Pfolt 267ssionals Nm:,ing I lor11c Sdltlul Summer Camp Wnrk Place Youth Spuds Notahh Cnscs hiiut ls Victim Adrn il i litdcr lnv stigntiun Rcsourc Nc seminars I.inks nnta I Page of4 nuU Wl SCS I Fanner Jaffe Weissing Page2 of4 Sexual Abuse I Sexual Assault Sexual Abuse victims ilrc ll flone and they have rights if and when they are ready to pursue them fner Jaffe Wcissing we want to empower victims to come fonyard report crimes and hold perpetrators accountable thereby educating the comniuriitya11d inspiring others to do the same Sexual Abuse Cases Under Investigation Looking for Witnesses in Alleged Sexual Abuse Cases We support crime viclimscascswith intensive factual and legal senrch We arc investigating the following matters and issues that clients and otherhnvc bro11ghuo our aUc11tion We are currently scnrching for witnesses lo assist-us in the following cases If.you have information please contact us re or call You can remain anonymous YOUTH PASTOR LONDON Olfr.law.firm is actiyety inv_estigating and representing victims claiming sexual abuse by fonner-Youth Pastor London Click video-below to.see exclusive interview http://w.ahuscandassault.com Abuse Undc1.._I nvestigatiori I n.uuse Wltnes_ses I Frirrner Jaffe Weissing Page3 of4 JEFFREY EPSTEIN RcgistcrcdScx Offender Our.law finn prosecutcdnumerouscivil cases against registered sex offender Jeffrey.Epstein He is known to have molested children in various places including his private airplahe He 1s a registered sex offender in Florida New York and the Virgi Islands Fhllida Sex Olfondcr Flyer Ne Yc,rk OITcnd Flyer Virgin Island Sex OITcndet FJvct If you have any information about his molestations of children or other crimes of his that are known to ou please call ot,r lnwfim1 If you were a former employee or a victim yourself have any information regarding his criminal activity please contact us Your nrune can rcmmn anonymous HOW CAN WE HELP YOU Full Name Email Address Phone Number ll Find us on Fucchonk ti!!:l Folio u.s on YuuTt1hl i hillmv tlS fl ionl!le Undcr_lnvestigatio11 Brief description of your issue Your Path to-j11stict1 Bt1,-ins tl/U cntfs rVith Us L!.PJll St::rnal Nntahk Cusls Ahout lls i:;ttUUII I sex Abuse Witnesses IFnrmerJnffe Weissing Vic.:tiiu 225katl 1lacl I I iwl:1imc1 Farmer a eissing Edwards Fistos Lehrman P.L Andrc sAvc Ste FtLnudcrdnle Florida Copyright Farmer Jaffe Vcissing Edwards Fisto Lehnnan P.L AH rights reserved Designed by DARD tarkcti11u I Powered by cOS Page of4 A A 4A E0 A4 DE a 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