Report In addition he has over years of experience in the United States Military dealing with computer science issues Report Dr Jansen has authored over academic publications focusing in the area of web analytics and related topics Report Most recently Dr Jansen was the testifying expert in the highly publicized trial of the sports reporter Erin Andrewss suit against Marriott International where he was qualified as an expert to analyze the dissemination of the unauthorized video of Ms Andrews on the Internet Report Dr Jansen is highly qualified to render an opinion in this case The work that he has performed in this case is entirely within his area of expertise as described above and outlined more fully in his curriculum vitae Dr Jansen was retained to analyze the extent of the dissemination on the Internet of the malicious accusations against Edwards raised in Epsteins lawsuit Depo pp Report Dr Jansen limited his work to include information from the date Epsteins lawsuit was filed until the day of his report in October Report During that time the primary allegations contained exclusively in Epsteins suit i.e that Edwards was involved in Rothsteins criminal conduct has been included in online media sites in separate stories or articles with a combined daily visitors Depo Report As explained in detail in his report and again in his deposition Dr Jansen conducted his web analytic work using the most reliable and conservative approach in the industry Depo Dr Jansen explained that it is not possible to look at the traffic to a page for a certain day or to view the readerships of a specific article Depo Dr Jansen therefore determined average daily traffic to a given site over the period of a week or a month Depo Report This is a reference to the transcript of Dr Jansens deposition taken on December which was attached as Exhibit to Epsteins Motion to Strike These figures are what are used in the industry to determine daily readership of websites Depo Report Dr Jansen took several measures to ensure his analysis was conservative For example he used the lowest number for the unique daily visitor count reported by the web analytic services so that the numbers would not be inflated His conservative approach also involved examining only on-line sources and not any print or broadcast media that included the information in question Depo Dr Jansen also did not include articles on websites for which he was unable to verify the visitor data to confirm the number of users Depo pp Report So out of the sites that contained articles with the language in question he included the traffic of only in his potential daily visitors total because he could not validate the traffic numbers for the other Depo He did not include numbers for multiple articles published by the same site with different publication dates Depo He also did not include the counts of those people who may have been searching using a site such as Google and saw the allegations in the search results listing Depo Additionally Dr Jansen did not include numbers for any dissemination of Epsteins malicious accusations beyond that of the actual visitors to the site in question Thus he did not count any times the articles were emailed or linked to another story not including the language in question here Depo Report or any face-to face dissemination Depo Report Finally as to the conservative aspect of Dr Jansens search he did not include dissemination of Epsteins false allegations against Edwards contained in the book Filthy Rich by James Patterson and John Connolly Depo Report This book was an account of the rise and fall so far of Jeffrey Epstein and includes the allegations raised by Epstein that Edwards was involved in Scott Rothsteins Ponzi scheme LEGAL ARGUMENT A Basic Standards for Admission of Expert Testimony Section Florida Statutes dealing with the admission of expert testimony provides If scientific technical or other specialized knowledge will assist the trier of fact in understanding the evidence or in determining a fact in issue a witness qualified as an expert by knowledge skill experience training or education may testify about it in the form of an opinion or otherwise if The testimony is based upon sufficient facts or data The testimony is the product of reliable principles and methods and The witness has applied the principles and methods reliably to the facts of the case Here Epstein argues only that Dr Jansens testimony is not relevant to any fact in issue and will not assist the trier of fact in understanding the evidence or in determining a fact in issue Dr Jansens Testimony is Admissible as it will Assist the Jury in Determining Plaintiffs Damages A claim for malicious prosecution is considered a personal tort Cate Oldham So.2d Fla citing Tatum Bros Real Estate Inv Co Watson So Fla The gravamen of the action is injury to character Tatum Bros So at citing Tidwell Witherspoon Fla As Epstein acknowledges Motion damages in a malicious prosecution action include damages to reputation shame humiliation and mental anguish Tatum Bros Real Estate Inv Co Watson So Fla Ware United States Supp M.D Fla recognizing that injury to reputation shame humiliation mental anguish and hurt feelings flowing from prosecution are all damages resulting from malicious prosecution see also Tackett Plastics Inc Bowsmith Inc So.2d Fla 2d DCA recognizing that harm to reputation humiliation embarrassment and mental suffering are valid damages in malicious prosecution action Turkey Creek Inc Londono So.2d Fla 1st DCA approved So 2d Fla noting that harm to reputation is a valid element of damages for malicious prosecution City of Coconut Creek Fowler So.2d Fla 4th DCA explaining that a malicious prosecution is a very ancient remedy to right a harm to reputation Many of these elements of damages in malicious prosecution claims are the same as elements of damages in defamation claims See Gertz Robert Welch Inc U.S Boyles Mid-Florida Television Corp So 2d Fla 5th DCA approved So 2d Fla Miami Herald Pub Co Ane So.2d Fla 3d DCA approved So 2d Fla see also Fla Stan Jury Instruct damages for defamation include injury to reputation shame humiliation mental anguish and hurt feelings Thus the fact that some elements of damages raised here and the evidence used to prove such damages may be the same as in a defamation case does not support Epsteins claim that Edwards is disguising an impermissible defamation claim within this malicious prosecution action In a malicious prosecution case the Oklahoma Supreme Court stated Browning Ray P.2d Okla General damages for injury to reputation and emotional or mental distress the precise amount of which by their very nature is almost impossible of proof and which damages almost certainly result if one has been maliciously prosecuted may be awarded if plaintiff has established the other essential elements of an action for malicious prosecution We recognize that the amount of such damages for injury to reputation and for distress will be determined at least in major part by the gravity of the offense charged and the publicity given the prosecution of plaintiff See also Shweitzer Sanchez P.2d N.M App citing Browning for same principle Additionally courts have evaluated the propriety of damage awards in malicious prosecution cases based in part on the amount of publicity attendant to the scurrilous charges See Colegrove City of Corning N.Y S.2d N.Y.A.D damages for malicious prosecution and false arrest were not excessive based on inter alia the attendant adverse publicity and its effect on the plaintiff his wife and his children Hardin Caldwell S.W 2d Tenn App damages awarded in malicious prosecution case not excessive because inter alia the widespread publicity of the charges Zenik Brian A.2d Conn damages awarded in malicious prosecution case not excessive based on the widespread publicity attendant oflitigation In fact the failure to document the publicity associated with the wrongful litigation can be relied on as a factor to limit the Plaintiffs damages See Jones Soileau So.2d La Epstein has not cited a single case holding that the extent of the publicity associated with the wrongful litigation is not a proper element of damages in a malicious prosecution case With respect to Dr Jansen it is clear he is an expert on the dissemination of information on the internet and he has used his expertise to track the dissemination of the injurious content of Epsteins wrongfully filed lawsuit As his testimony clearly demonstrated he focused on the subject matter of the false allegations that Edwards was involved in the criminal activity of Rothstein and the underlying Ponzi scheme Tracking the dissemination of that information which emanated from the wrongful lawsuit filed by Epstein requires an expert given the technical complexities of tracking data on the internet The information provided by Dr Jansen is certainly outside the purview of the typical juror Evidence requiring technical computer knowledge beyond the expertise of a typical lay juror as to an issue in the case is generally admissible See Marten Transp Ltd Plattform Advert Inc Supp 3d Kan holding that testimony of computer consultant with experience in computer forensics and data recovery offered expertise beyond that of the typical lay juror concerning search techniques including the use of internet archives would be helpful to a jury Khoday Symantec Corp Supp 3d Minn as amended Apr holding that testimony of web archive manager admissible because his specialized knowledge of the website archiving and retrieval process would offer assistance to the jury in understanding the issues in the case Epstein argues that Dr Jansens testimony will not help the trier of fact because he did not testify whether the malicious suit filed against Edwards by Epstein caused Edwards shame humiliation mental anguish and hurt feelings Motion This argument is misplaced All relevant evidence is admissible Evidence is relevant if it tends to prove or disprove a material fact Here Dr Jansens testimony is relevant to the issue of damages suffered as a result of Epsteins malicious prosecution of Edwards Because the extent of the dissemination of the false claims made by Epstein bears directly on how much shame humiliation and mental anguish Edwards has suffered Dr Jansen testified at his deposition that the allegations raised in Epsteins suit against Edwards that he was a participant in Scott Rothsteins Ponzi scheme were disseminated on media sites in different articles Based upon conservative figures Dr Jansen opined that those articles reached at least people This testimony establishes the scope of the dissemination of the false and malicious accusations raised against Edwards in Epsteins suit That testimony is without a doubt relevant as to whether and to what degree Edwards suffered damages such as harm to reputation humiliation and mental anguish Dr Jansen is not attempting to be an expert on monetizing Plaintiffs intangible losses nor on the causation of Plaintiffs intangible damages And he does not need to be an expert on those subjects to assist the jury or to present admissible testimony It is well-settled that the determination of the amount of intangible damages in personal injury tort actions is peculiarly within the province of the jury Bould Touchette So.2d Fla That principle has been specifically applied in Florida to damages in malicious prosecution cases See McDonald Sport So.2d Fla 3d DCA Maiborne Kuntz So.2d Fla Schlesser Levinson So.2d Fla th DCA Thus no expert is authorized to testify as to a methodology for monetizing a Plaintiffs intangible damages Epstein claims that Dr Jansens testimony should be excluded because he could not specifically testify that all the hits on the websites which disseminated the critically false information actually demonstrate people who viewed that subject matter This fact does not make the testimony any less relevant or helpful to a jury As discussed above Dr Jansen used extremely conservative methods establishing the numbers of articles published websites hosting and daily unique visitor traffic The testimony is relevant to establish the size of readership of the media sites in question It will certainly be helpful for the jury to understand the scope and the spread of the sites in determining whether Edwards was in fact damaged by dissemination of the relevant articles on the sites For instance according to Dr Jansen the Palm Beach Daily News has average daily unique traffic of visitors and the Miami Herald has average daily traffic of visitors If the jury were to hear that the articles were disseminated only on the Palm Beach Daily News website on one occasion it would certainly evaluate Edwardss claim different by than if the articles were also disseminated in the Palm Beach Post New York Daily News unique daily visitors and Forbes daily unique visitors Additionally Epsteins argument runs directly into a fundamental principle of jurisprudence that a defendant cannot benefit from his own wrongdoing In Bigelow RKO Radio Pictures U.S The most elementary conceptions of justice and public policy require that the wrongdoer shall bear the risk of the uncertainty which his own wrong has created That principle is an ancient one and is not restricted to proof of damage in antitrust suits Citations omitted In this case Epstein maliciously filed a false lawsuit against Edwards accusing him of criminal conduct racketeering and participation in a massive Ponzi scheme which Epstein knew was receiving nationwide publicity As is apparent from the context of his filing the lawsuit Epstein intended that it would harm Edwards not only in his reputation but also in the performance of his profession more particularly his ability to pursue civil actions against Epstein on behalf of Edwardss clients L.K E.W and Jane Doe Epstein obviously knew and intended that Edwards reputation would suffer from this lawsuit and that such harm is difficult to remedy and to quantify He should not be heard now to argue that Edwards evidence in this case expert testimony from a highly qualified witness utilizing established methodologies is incompetent to provide the jury guidance in determining the appropriate damages The Florida Supreme Court has stated McCall Sherbill So.2d Fla There are many types of cases in which the damages may be certain but the amount of damage may be uncertain However such uncertainty will not necessarily preclude recovery More specifically the Court has recognized that some degree of speculation is inherent in any jury award for intangible damages Seaboard Coast Line Co McKelvey So.2d Fla Quite obviously some speculation enters into most personal injury actions but the yardstick does not exist which can measure future humiliation pain and suffering of the injured with sufficient certainty to divest a jury of exercising its sound discretion to determine the damage award based upon the evidence and merits of each case under consideration Dr Jansens testimony provides a valuable aid to the jury in assessing the scope of dissemination of Epsteins false charges Thus while some degree of speculation is inherent in any jury award of intangible damages that is not a basis to exclude his testimony Epstein acknowledges that the trial court has wide discretion in determining which matters are proper subjects of expert opinion testimony citing Bryant Buerman So.2d Fla th DCA Motion Epstein does not dispute that Dr Jansen has a recognized expertise that he applied in analyzing the dissemination of the gravamen of Epsteins malicious lawsuit As such Epstein does not provide a basis to demonstrate that this Court is compelled prior to trial to exclude Dr Jansens testimony He has also cited no comparable case in which the exclusion of such testimony occurred Epsteins criticisms of the limited nature of Dr Jansens testimony can be raised during cross-examination of the expert because they go the weight of the testimony not admissibility See Florida Dept ofTransp Armadillo Partners Inc So 2d Fla The definition of relevant evidence is evidence tending to prove or disprove a material fact Fla Stat Here Dr Jansens testimony tends to prove that the false gravamen of Epsteins suit against Edwards was widely disseminated throughout the internet to multiple websites which were viewed by millions of people during the relevant time period As noted previously the extent of the publicity of the scurrilous lawsuit is a relevant consideration in determining the Plaintiffs damages This is true not only for the intangible losses associated with reputational damage but also the shame and humiliation experienced by the Plaintiff in being subjected to that adverse publicity which had no foundation in fact Epstein does not cite any particular principle of admissibility that justifies exclusion of Dr Jansens testimony Instead he criticizes Dr Jansen for issues he did not address such as causation and the monetization of Plaintiffs intangible damages However that is frankly irrelevant to this Courts determination The question is whether Dr Jansens testimony is helpful to the jury in determining the extent of the dissemination of the critical subject matter of Epsteins lawsuit against Edwards Clearly Dr Jansens testimony will be helpful to the jury in evaluating the damage to the Plaintiff by defining the scope of the internet dissemination of Epsteins false charges That is information that a layperson would not be qualified to access and of course would not be permitted to investigate themselves as members of the jury See Fla.Std.Civ.Jur.Ins In Angrand Key So.2d Fla the Florida Supreme Court authorized the admission of testimony of psychiatrist psychologist or other qualified professionals on the issue of the pain and suffering caused by the death of a survivors decedent In that situation the expert obviously was not monetizing the loss yet it was deemed helpful and admissible to assist the jury in evaluating the intangible losses In Acree Hartford South Inc So.2d Fla th DCA the court authorized the admission of testimony of an expert on human perception regarding how an average alert driver could fail to see two people who ran in front of his truck In that case the expert could not specifically testify as to causation of the accident at issue nor testify as to the particular perceptions or conduct of the defendant Nonetheless that testimony was deemed helpful to the jury in evaluating the issues before it Epsteins Irrelevant Arguments This is not a defamation action Epstein refuses to accept what has already been established in this case Edwards has stated a valid cause of action for malicious prosecution Epsteins repeated claims that Edwards is actually improperly pursuing a defamation claim must be rejected once again Although some of the elements of damages of a malicious prosecution claim may be the same as those that may arise in a defamation claim that does not convert the cause of action into a defamation case Loss of reputation shame and humiliation are valid damages caused by the distinct effect of a malicious prosecution just as they are in a defamation action Epsteins Motion quotes from pleadings and discovery and suggests that because the word defamation or the phrase defamatory per se were utilized at various times that this must be a defamation action There is no logic to that contention Defamation is a generic term as indicated from the following definition in the Merriam Webster dictionary the act of communicating false statements about a person that injur the reputation of that person Similarly defamatory per se while certainly having particular application in defamation cases is also generically defined as a statement that is defamatory in of itself and is not capable of an innocent meaning Blacks Law Dictionary th Ed One of the essential elements of a malicious prosecution claim is that the allegations in the wrongfully filed lawsuit against the plaintiff be without merit and that there was an absence of probable cause for alleging them Obviously that means that there must be false material contained within the charging document that is disproved or abandoned in the underlying case resulting in a bona fide termination in favor of the plaintiff As noted above the damages available in a malicious prosecution action include the damages to the plaintiffs reputation and the shame and humiliation caused by the false charges Thus false statements are an inherent part of any malicious prosecution case and the impact of those charges and their dissemination are directly linked to the issue of damages Epstein contends that a malicious prosecution action focuses on the civil proceeding and not handpicked allegations which is irrelevant to Dr Jansens testimony Dr Jansens work involved tracking the dissemination of the critical subject matter of Epsteins malicious lawsuit i.e that Edwards was involved in the criminal conduct masterminded and implemented by Rothstein That cannot be characterized as a handpicked allegation but rather was the gravamen of Epsteins scurrilous lawsuit which damaged Edwards Therefore the Court should ignore that irrelevant argument Epsteins motion makes many arguments that have no application to the admissibility of Dr Jansens testimony These include taking issue with an allegation in Epsteins complaint that Edwards knew or should have known that the three civil actions he filed against Epstein were weak Dr Jansen did not do any search of the internet regarding the subject matter of the three civil cases brought against Epstein for sexual molestation and whether they were weak Thus this subject has no place in this motion which challenges Dr Jansens testimony and therefore it should be ignored Epstein also falsely claims that Edwards has admitted to having no reputational damage Motion relying primarily on statements that Edwards has worked hard subsequent to the filing of Epsteins malicious lawsuit in to resurrect his reputation among those in the local community who know him That is not the equivalent of an admission of no reputational damages nor is the fact that Edwards is not seeking economic damages for lost income As noted previously extensive case law in Florida holds that a plaintiff in a malicious prosecution action is entitled to recover intangible damages for the loss of reputation as well as the shame and humiliation suffered as a result of the maliciously prosecuted litigation Moreover that issue is entirely independent of the admissibility of Dr Jansens testimony Finally Epstein resurrects his contention that the litigation privilege applies However the Fourth District ruled against him as a matter oflaw and he conceded in the Florida Supreme Court that its decision in Debrincat Fischer So.3d Fla resolved that issue As a result that determination is law of the case Moreover that issue has no logical relationship to the admissibility of Dr Jansens testimony CONCLUSION Epstein has set forth no valid reason for excluding the expert testimony of Dr Jansen The jury should have the benefit of hearing Dr Jansens testimony on the mass dissemination of the malicious claims Epstein raised against Edwards For the reasons discussed above Epsteins Motion to Strike Expert Witness Dr Bernard Jansen and to Exclude His Testimony must be denied I HEREBY CERTIFY that a true copy of the foregoing was furnished to all counsel on the attached service list by email on January kbt Jack Scarola Esq SEARCY DENNEY SCAROLA BARNHART SHIPLEY P.A Palm Beach Lakes Blvd West Palm Beach FL eservice searcylaw.com jsx searcylaw.com and BURLINGTON ROCKENBACH P.A Courthouse Commons/Suite West Railroad A venue West Palm Beach FL Attorneys for Bradley Edwards pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com By:/s Philip Burlington PHILIP BURLINGTON Florida Bar No By:/s Nichole Segal NICHOLE SEGAL Florida Bar No SERVICE LIST Epstein Rothstein/Edwards Case No Scott Link Esq Kara Rockenbach Esq Angela Many Esq LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach Florida Scott linkrocklaw.com Kara linkrocklaw.com Troy linkrocklaw.com Eservice linkrocklaw.com Tina linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com Attorneys for Jeffrey Epstein Mark Nurik Esq LAW OFFICES OF MARC NURIK Broward Blvd Ste Fort Lauderdale FL marc nuriklaw.com Attorneys for Scott Rothstein Jack Goldberger Esq ATTERBURY,GOLDBERGER WEISS P.A Australian Ave Ste West Palm Beach FL jgoldberger agwpa.com smahoney agwpa.com Attorneys for Jeffrey Epstein Bradley Edwards Esq FARMER JAFFE WEIS SING EDWARDS FISTOS LEHRMAN P.L Andrews Ave Ste Fort Lauderdale FL staff.efile pathtojustice.com brad pathtojustice.com U?vO?OP?F3O G?M?tI?OO?G0 W?ii?W8x??I7 I K?K A o(o3oBz 4K 30KCb 2e p2t 2A A Q?8F JK TZ N?M?r NEeD?M rq A WS?nY?GE mR?d YBWY xy?u?u i hSKI 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