Filing E-Filed PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff I PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS NOTICE OF FILING SUPPLEMENTAL AUTHORITY IN SUPPORT OF HIS OBJECTION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS REQUEST FOR JUDICIAL NOTICE PURSUANT TO FLORIDA STATUTES SECTIONS AND Plaintiff/Counter-Defendant Jeffrey Epstein Epstein hereby provides the Court with supplemental authority in support of his Objection to Defendant/Counter-Plaintiff Bradley Edwards Edwards Request for Judicial Notice Pursuant to Florida Statutes section and as follows I Dolan State So 3d Fla 2d DCA The Second District Court of Appeal held that ooking information obtained from a sheriffs website does not fall within the list of matters for which a court must take judicial notice under section and it does not appear to fall within the list of matters for which a court may take judicial notice under section Emphasis added Exhibit A FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Nationwide Mutual Fire Insurance Company Darragh So 3d Fla 5th DCA the Fifth District Court of Appeal held that website materials were inadmissible hearsay and cited with approval St Lukes Cataract and Laser Inst P.A Sanderson WL M.D Fla May which held that Web-sites are not self-authenticating To authenticate printouts from a website the party proffering the evidence must produce some statement or affidavit from someone with knowledge of the website for example a web master or someone else with personal knowledge would be sufficient Exhibit 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 PA 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 Trial 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 jsx searcylaw.com njs FLAppellateLaw.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 Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein EXHIBIT A Dolan State So.3d a Week Synopsis So.3d District Court of Appeal of Florida Second District Roland DOLAN Appellant STATE of Florida Appellee No I Feb Background Defendant was convicted in the Circuit Court Pasco County William Webb of felony battery Defendant appealed Holdings The District Court of Appeal Altenbernd held that defendants prior booking photo was not admissible to prove his prior conviction in the absence of any predicate testimony and copy of certified judgment without fingerprints was insufficient to prove that defendant was the person identified in the judgment Reversed and remanded Appeal from the Circuit Court for Pasco County William Webb Judge Attorneys and Law Firms Howard Dimmig II Public Defender and Kevin Briggs Assistant Public Defender Bartow for Appellant Pamela Jo Bondi Attorney General Tallahassee and Gillian Leytham Assistant Attorney General Tampa for Appellee Opinion ALTENBERND Judge Roland Dolan appeals his judgment and sentence for a felony battery under section Florida Statutes which required the jury to determine as an element of the offense that Mr Dolan had committed a prior battery Although there is a very high probability that Mr Dolans record includes a conviction for a prior battery the State did not present sufficient admissible evidence of any prior conviction for battery before it rested and the courts actions thereafter did not effect a proper introduction of evidence This case presents several interesting issues that should concern prosecutors who must prove to a jury the existence of a prior misdemeanor conviction as an essential element of an offense in a county like Pasco County where older misdemeanor judgments do not always contain the fingerprints contemplated by Florida Rule of Criminal Procedure Our holding however is limited to the decision that the sua sponte procedure used by the trial court in this case was not a proper procedure to admit evidence of a prior conviction Accordingly we reverse the judgment and sentence on appeal and remand for entry of a judgment and sentence for misdemeanor battery I THE FACTS AND PROCEEDING IN CIRCUIT COURT On December Mr Dolan was a cab driver In the early evening he picked up a mother and her daughter outside of the emergency room of a hospital where the daughter had received treatment While driving the two passengers home Mr Dolan drove in a manner that frightened the passengers They ordered him to pull over and to stop When he finally pulled off the road and stopped the daughter got out of the vehicle and called the police Mr Dolan became angry and struck the mother who was still in the vehicle He also spat on her and called her names An officer arrived at the scene He interviewed Mr Dolan and the two passengers and collected written statements from the two passengers The officer established probable cause to believe that Mr Dolan had a prior battery conviction and arrested him for felony battery The State initially charged Mr Dolan with five offenses but he was convicted only of felony battery He received a sentence of ten months incarceration in county jail followed by one year of community control and two years WESTLAW Thomson Reuters No claim to original U.S Government Works Dolan State So.3d a Week of probation The trial court bifurcated the jury trial The first phase of the trial concerned whether Mr Dolan was guilty of battery The second phase of the trial concerned whether Mr Dolan had the requisite prior record to be convicted of felony battery The issue on appeal involves only the second phase of this proceeding During the second phase the State presented no witnesses It relied exclusively on what it asserted was a prior judgment of conviction for a misdemeanor battery While the jury was deliberating on the first phase the trial court asked the State how it intended to prove a prior conviction The State responded that it had a certified copy of a prior judgment and sentence The trial court observed that the document did not contain fingerprints The court asked the State to provide legal precedent that would support the admission of a judgment that did not contain fingerprints The State assured the court that it would find the precedent After the jury returned its first verdict of guilt the State informed the trial court that it had the certified copy of the judgment and sentence and a copy of a booking photo in its possession But the State provided no legal precedent to support the introduction of the certified copy without fingerprints Instead the assistant state attorney stated But at this time we dont have any and then well just ask for you to take judicial notice ofit after entering the judgment and sentence and if the jury finds it to be the defendant and then theres a challenge from the defense then we would argue with the booking photo Thats our game plan at this point Not surprisingly the defense objected to this rather odd game plan The trial court advised that it would simply allow the State to proceed with its evidence and then address the matter in a motion for judgment of acquittal When the State sought to introduce the certified copy of a judgment and sentence into evidence Mr Dolans attorney objected that the State had presented no evidence that the person listed in the judgment was actually the defendant The trial court decided to allow it into evidence after first denying the objection which it characterized as an objection based on relevancy The court added But of course if they cant show relevancy Ill grant your motion for a directed judgment of acquittal as to this bifurcated portion of the trial Once the court admitted this exhibit into evidence the State rested Recognizing that we may be Monday-morning quarterbacks this probably would have been a good time for the trial court to allow Mr Dolans attorney to move for a judgment of acquittal Instead the trial court conducted a bench conference asking the State how it had identified the defendant as the person named in the prior judgment The State responded that it wanted the court to take judicial notice of a booking photo The court responded What booking photo The assistant state attorney having already rested said The booking photo online but I have a copy of it It wasnt entered into evidence thats why its something that can be ascertained by the Court We didnt enter it into evidence because we dont have the person that took the photo But the booking photo has the case number attached to it Mr Dolans attorney then objected to this entire procedure The trial court never actually announced that it was going to take judicial notice of the online information from the sheriffs website Instead it asked Madam Clerk do you have some scissors Okay Do you have some staples stapler Mr Dolans attorney asked to make an argument and the court announced that it had already heard argument The court then stapled a redacted copy of the online internet material to the certified judgment Thereafter the State moved to reopen its case The court asked But now youre resting Mr Dolans attorney responded that the State had already rested to which the court replied Oh Ill allow them to reopen their case I dont play those games Mr Dolans attorney then moved unsuccessfully for a judgment of acquittal The trial court never actually took judicial notice of any document and the jury was not told that the court had taken judicial notice Instead the State argued to the jury that it should look at the booking photo and then at the defendant in the courtroom and decide if it was the same person The jury returned a verdict in favor of the State WESTLAW Thomson Reuters No claim to original U.S Government Works Dolan State So.3d a Week After sentencing Mr Dolan appealed his judgment and sentence II THE HOLDING The applicable felony battery statute states in part A person who has one prior conviction for battery aggravated battery or felony battery and who commits any second or subsequent battery commits a felony of the third degree punishable as provided in section ection or section For purposes of this subsection conviction means a determination of guilt that is the result of a plea or a trial regardless of whether adjudication is withheld or a plea of nolo contendere is entered Fla Stat There can be no dispute that a prior conviction in this context is an element of the offense See State Rothwell So.2d Fla 1st DCA Accordingly unless the defendant waives a jury trial on this issue the prior conviction is a factual issue that must be proven beyond a reasonable doubt to the jury cut and paste a copy of a redacted online document to a certified judgment The court effectively introduced its own evidence against the defendant thereby departing from its required position of neutrality See Seago State So.3d Fla 2d DCA Any argument that a copy of an online document even a document from a government website can be admitted into evidence over objection to prove an essential element of a third-degree felony without any predicate testimony to establish its authenticity or to prove the truth of its content i.e that it is a battery judgment involving the defendant borders on the frivolous See Fla Stat relating to the admission of public records We do not believe that the trial court actually took judicial notice of the booking photo To do so would have been error in this case Although case law permits a trial court at least in a nonjury trial to take judicial notice of a fact essential to a criminal conviction the circumstances in which this is permissible are quite narrow See e.g Cordova State So.2d Fla 3d DCA Booking information obtained from a sheriffs website does not fall within the list of matters for which a court must take judicial notice under section and it does not appear to fall within the list of matters for which a court may take judicial notice under section Even if this booking document were such information an oral request to take judicial notice of such evidence after a party has rested its case would clearly fail to comply with the procedures of section which addresses the circumstances requiring compulsory judicial The trial courts bifurcated proceeding to prevent notice of items listed in section the presentation of evidence of the prior record to the jury during the initial stage of the trial was an entirely appropriate procedure in this case Cf State Rodriguez So.2d concluding that if a defendant charged with felony DUI elects to be tried by jury the court shall conduct a jury trial on the elements of the single incident of DUI at issue without allowing the jury to learn of the alleged prior DUI offenses and that if the jury returns a guilty verdict the trial court shall conduct a separate proceeding to determine if the defendant has the requisite prior convictions footnote omitted modified by State Harbaugh So.2d Fla.20 holding that unless waived by the defendant in a felony DUI case the jury not the judge must decide the issue of the defendants prior convictions in the second phase of the trial But the odd procedure utilized by the court to introduce the prior judgment is improper It was not the State that asked the court to We recognize that the Fourth District allowed a trial court in a bifurcated felony DUI proceeding to take judicial notice of an entire court file that contained among other things a booking photograph See Ward State So.2d Fla 4th DCA cf Williams State So.2d Fla 4th DCA distinguishing Ward and explaining that it sustained a conviction in Ward even though all the required past offenses were not proven with certified copies of the judgments of conviction because the state supported the evidence of the defendants DMV driving record with other reliable evidence of the conviction If the State had had an entire court file from a prior misdemeanor conviction in this case the outcome might have been different But see Stoll State So.2d Fla.20 Although a trial court may take judicial notice of court records it does not WESTLAW Thomson Reuters No claim to original U.S Government Works Dolan State So.3d a Week follow that this provision permits the wholesale admission of all hearsay statements contained within those court records citation omitted Perhaps the assistant state attorney in this case was inexperienced Nonetheless while a trial court certainly has some discretion to make allowances for inexperienced or unprepared attorneys the court does not have the discretion to dispense with basic rules of evidence or to take over the role of prosecutor Thus we hold that the trial court erred in admitting this odd document using these unusual procedures The trial court should have granted a judgment of acquittal as to the felony charge when the State was unprepared to prove that the defendant was the person identified in the prior judgment Accordingly on remand the trial court shall enter a judgment for misdemeanor battery I THE UNRESOLVED ISSUES Mr Dolan argues that the prior judgment could not be admitted as evidence of a conviction because it did not contain fingerprints in compliance with Florida Rule of Criminal Procedure Relying on Keith State So.2d Fla 2d DCA he claims the document is thus inadmissible unless the State provides the whole record as described in Warren State So.2d The State answered with a brief that relied extensively on case law that discussed the admission of prior convictions in various contexts The rules for the admission of prior convictions for purposes of sentencing or when the prior conviction is not an essential element to be determined by a jury are simply different than those applicable to this case See Sustakoski State So.2d Fla 4th DCA holding that a fingerprint match is not essential for a conviction to be used as a qualifying offense for purposes of a violent career criminal sentence Johnson State So.2d Fla 4th DCA stating that the evidence was sufficient to prove identity for the purpose of considering two prior convictions on the defendants sentencing scoresheet despite a lack of fingerprints Wence State So.2d Fla 4th DCA holding that under the Prisoner Footnotes Releasee Reoffender Act the State must only prove that the defendant and the releasee identified by the Florida Department of Corrections are one and the same person by the preponderance of the evidence and that it may do so through photographic evidence Additionally much of the related case law including Keith dealt with proof of a prior felony conviction as opposed to a prior misdemeanor conviction Rule which provides a form judgment requiring fingerprints on its face states that the form shall be used by all courts The rule however appears to have been written to comply with chapter Laws of Florida and section Florida Statutes which require fingerprints to be affixed to every written judgment reflecting guilt of a felony See In re Fla Rules of Criminal Procedure So.2d Our record obviously contains no information about when the county court in Pasco County or the county courts in other counties began to use a form judgment that included fingerprints No one in this case argues that the legislature has required fingerprints on misdemeanor judgments as a matter of substantive law Because the State did not attempt to comply with the proper procedures for judicial notice in this case our record tells us nothing about the nature of the public records maintained in Pasco County for prior simple battery or DUI convictions Given that convictions for these types of offenses are some of the most common convictions to be used as substantive proof to establish subsequent felony charges we decline to announce any rule governing the admissibility of evidence establishing the historical fact of the prior conviction at this time Suffice it to say if the absence of fingerprints on misdemeanor judgments has been a common longstanding practice in Pasco County it is a legal issue that prosecutors will need to address with care until precedent is established on this issue Reversed and remanded Dolan State So.3d a Week The judgment erroneously reflected that Mr Dolan was convicted of felony battery pursuant to section of the Florida Statutes That opinion at least suggests that the second phase of the trial was nonjury Ward State So.2d Fla 4th DCA Mark Ward timely appeals after a jury in a bifurcated proceeding convicted him of driving under the influence DUI The trial court determined the felony portion of this DUI charge End of Document Thomson Reuters No claim to original U.S Government Works WESTLAW Thomson Reuters No claim to original U.S Government Works EXHIBIT Nationwide Mut Fire Ins Co Darragh So.3d Fa Weeky Synopsis So.3d District Court of Appeal of Florida Fifth District NATIONWIDE MUTUAL FIRE INSURANCE COMP ANY Appellant Mark DARRAGH Appellee No I June I Rehearing Denied July Background Insured brought action against insurer that provided in uninsured motorist UM coverage seeking damages arising out of automobile accident The Circuit Court Seminole County Michael Rudisill entered judgment on a million jury verdict in favor of insured that included an award of future economic damages Insurer appealed Holdings The District Court of Appeal Lawson held that trial court erred in refusing to instruct jury to reduce its award of future economic damages to present value insured could present testimony as to the full amount of his past medical bills and information and printouts from government website concerning expected military retirement benefits were not admissible Affirmed in part reversed in part and remanded Attorneys and Law Firms Richard A Sherman Sr of Richard A Sherman P.A Fort Lauderdale and Sonya Wesner of the Law Office of Patricia Garagozlo Orlando for Appellant Jeffrey Byrd of Jeffrey Byrd P.A Orlando for Appellee Opinion LAWSON,J Nationwide Mutual Fire Insurance Company appeals from a final judgment entered following a million jury verdict entered in favor of Nationwides insured Mark Darragh Nationwide provided uninsured motorist coverage in the amount of to Darragh We agree with Nationwide that the trial court erred in refusing to instruct the jury to reduce future economic damages to present value in rendering its verdict See Dupuis Heider Fla So Florida East Coast Ry Co Young Fla So Florida East Coast Ry Co Lassiter Fla So Milton Reyes So.3d Fla 3d DCA Howell Woods So.2d Fla 4th DCA Seaboard Coast Line RR Co Burdi So.2d Fla 3d DCA Seaboard Coast Line RR Co Garrison So.2d Fla 2d DCA Norman Mullin So.2d Fla 2d DCA Accordingly we reverse the portion of the verdict awarding future economic damages and remand for a new trial as to future economic damages only See e.g Milton So.3d at We find no error in the trial courts decision to allow testimony of the full amount of Darraghs past medical bills pursuant to section Florida Statutes and Goble Frohman So.2d The trial court properly treated the lesser amount negotiated for payment by Darraghs private health insurer as a collateral source set-off to be made by the judge after trial See Nationwide Mut Fire Ins Co Harrell So.3d Fla 1st DCA For the benefit of the parties and the trial court on retrial we address one other evidentiary issue relating to Darraghs future economic damages claim Over Nationwides many and various objections Darragh was allowed to personally testify as to the value of future pension benefits that he claims to have lost from the United States military as a result of injuries sustained in the underlying automobile accident It appears that Darragh based this testimony exclusively on information he gleaned from websites maintained by the United States government Copies of pages from these websites WESTLAW Thomson Reuters No claim to original U.S Government Works Nationwide Mut Fire Ins Co Darragh So.3d Fa Weeky were also introduced into evidence over Nationwides objections We agree with Nationwide that the trial court erred in permitting this testimony and admitting printed copies of the website pages into evidence on this record The website materials attempt to simplify and explain in lay terms how one can estimate the amount of future potential military retirement benefits with the following cautions These results are based on your assumptions The future will differ from these assumptions and actual results will differ correspondingly Remember these results are not guaranteed they are merely estimates This point cannot be emphasized too heavily there is no guarantee that the assumptions will all prove correct This is why you should play with the assumptions The intent of this analysis is to help you to make a fairly simple and direct estimate of the financial flow resulting from your retirement and be able to investigate some of the factors that influence the result Nationwides objections to the admission of these documents at trial included a hearsay objection and an objection that the documents had not been properly authenticated Darragh countered the hearsay objection by arguing that the website pages fell within the hearsay exception for public records and reports in section Florida Statutes but made no attempt to authenticate them as such See e.g Jacksonville Elec Auth Dept of Rev So.2d Fla 1st DCA Public records and reports are admissible as an exception to the hearsay rule section provided they are authenticated section by a custodian sections and see also St Lukes Cataract and Laser Inst P.A Sanderson WL M.D.Fla May Web sites are not self-authenticating To authenticate printouts from a website the party proffering the evidence must produce some statement or affidavit from someone with knowledge of the website for example a web master or someone else with personal knowledge would be sufficient citations omitted Darraghs argument below and on appeal also fails to recognize that section limits admissibility of public records to those setting forth the activities of the office or agency or matters observed pursuant to duty imposed by law as to matters which there was a duty to report The government website printouts admitted below do not simply set forth the activities of a government agency or matters observed pursuant to a duty to report Cf Sikes Seaboard Coast Line RR Co So.2d Fla 1st DCA finding Florida Drivers Handbook did not fall under either category of public record admissible under section Accordingly the trial court erred in admitting these website printouts under the public records exception Darragh alternatively argues that the government website information was admissible under section which allows a court to take judicial notice of facts that are not subject to dispute because they are capable of accurate and ready determination by resort to sources whose accuracy cannot be questioned We agree that some of the factual tables copied from the website would qualify for judicial notice under section However to rule the basic attempt to explain and simplify into lay terms the assumptions and calculations necessary to estimate future potential retirement benefits admissible pursuant to section would be inconsistent with the principles underlying our jury system As explained in Maradie Maradie So.2d Fla 1st DCA In our justice system the practice of taking judicial notice of adjudicative facts should be exercised with great caution This caution arises from our belief that the taking of evidence subject to established safeguards is the best way to resolve disputes concerning adjudicative facts When a matter is judicially noticed it is taken as true without the necessity of offering evidence by the party who should ordinarily have done so Thus historically judicial notice applies to self-evident truths that no reasonable person could question truisms that approach platitudes or banalities Id at internal citations omitted quoting Makos Prince So.2d and Hardy Johns Manville Sales Corp F.2d 5th In short if this authoritative source can be admitted into evidence simply because the trial court can readily verify that it is an authoritative source the same rule should apply to other authoritative sources It does not Rather under our evidence code statements of facts or opinions on a subject of specialized knowledge contained in a published treatise or other authoritative writing may only be used in cross-examination of an expert witness Fla Stat Section WESTLAW Thomson Reuters No claim to original U.S Government Works Nationwide Mut Fire Ins Co Darragh So.3d Fa Weeky does not permit statements in a learned treatise to be used as substantive evidence since the treatise would be hearsay if offered as substantive evidence Donshik Sherman So.2d Fla 3d DCA This is so because the opposing party cannot cross-examine and impeach the source of the hearsay Duss Garcia So.3d Fla 1st DCA quoting In re S.E So.2d Fla 2d DCA This was one of the primary arguments that Nationwide made to the trial court and repeated on appeal that by admitting the website information into evidence and allowing Darragh to testify from it Nationwide had no way to test the methods assumptions and underlying explanations for Darraghs ultimate conclusions On this record we agree Finally Darragh alternatively argues that his testimony on this issue was based upon formulas easily gleaned from federal statutes and that the trial court properly took judicial notice of these statutes Clearly a trial court is authorized to take judicial notice of a federal statute See Fla Stat The problem here is that we cannot find the information forming the basis of Darraghs testimony in any of the statutes Darragh cites Although Darraghs counsel argued that the website information mirrored federal law Footnotes he did not provide copies of the statutes themselves only citations And the information is simply not readily apparent from the cited statutes If on remand Darragh can locate a statute that plainly lays out a mathematical formula for calculation of his claimed retirement benefit we would agree that Darragh could plug the numbers into that formula without the aid of an expert witness thus providing a basis for the jurys consideration of this element of future economic damages But on this record we agree with Nationwide that simply admitting the website pages and allowing Darragh to testify from them was improper As to all other issues we affirm the jurys verdict and the trial courts final judgment AFFIRMED IN PART REVERSED IN PART AND REMANDED COHEN and JACOBUS JJ concur All Citations So.3d Fla Weekly At trial Nationwide requested that the jury be instructed as to this issue using Standard Jury Instruction The trial court declined to give the instruction after hearing argument from Darraghs counsel who believed that the case law requiring a trial court to instruct the jury to reduce future economic damages to present value had been superceded by an amendment to section Florida Statutes in See Ch Laws of Fla Contrary to Darraghs argument the requirement that a jury be instructed upon request to reduce future economic damages to their present value was a common law requirement that pre-dated the enactment of section Florida Statutes by many decades-as can be seen from the cases cited above dating back to Section was originally enacted as part of the Tort Reform Act of see Ch Laws of Fla and required the trier of fact in negligence actions to itemize its verdict into economic losses noneconomic losses and punitive damages Subsection two required further itemization between past and future losses and required future economic losses to be computed on the verdict form itself before and after reduction to present value Id The amendment simply removed the requirement for an itemized verdict form reflecting the present value calculation Ch Laws of Fla Contrary to Darraghs argument the legislatures decision to remove the requirement that a jury detail its present value calculation on an itemized verdict form cannot be read as abrogating the longstanding common law requirement that a jury be instructed to reduce future economic damages to present value See e.g Essex Ins Co Zota So.2d A statute designed to change the common law rule must speak in clear unequivocal terms for the presumption is that no change in the common law is intended unless the statute is explicit in this regard quoting Carlile Game Fresh Water Fish Commn So.2d End of Document Thomson Reuters No claim to original U.S Government Works WESTLAW Thomson Reuters No claim to original U.S Government Works A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a 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