Edwards adv Epstein Case No Memorandum of Law Page of23 Turning to the merits of the case Auriemme contends that it was error to deny his two challenges for cause thereby forcing the exhaustion of his peremptory challenges We agree based on the applicable test found in Hill State So.2d Fla This Court recently stated The test for determining juror competency is whether the juror can lay aside any bias or prejudice and render his verdict solely upon the evidence presented and the instructions on the law given to him by the court Lusk State So.2d Fla cert denied U.S S.Ct L.Ed.2d In applying this test the trial courts must utilize the following rule set forth in Singer State So.2d Fla If there is a basis for any reasonable doubt as to any jurors possessing that state of mind which will enable him to render an impartial verdict based solely on the evidence submitted and the law announced at the trial he should be excused on motion of a party or by the court on its own motion Id at In Singer we reaffirmed the proposition that the statement of a juror that he can readily render a verdict according to the evidence notwithstanding an opinion entertained will not alone render him competent if it otherwise appears that his formed opinion is of such a fixed and settled nature as not readily to yield to the evidence Id at quoting Olive State Fla So h1 other early cases this Comt stated that Jurors should if possible be not only impaitial but beyond even the suspicion of partiality OConnorv State Fla and that if there is a doubt as to the jurors sense of fairness or his mental integrity he should be excused Johnson Reynolds Fla So A juror should be excused for cause if there is a doubt as to jurors sense of fairness or mental integrity Johnson Reynolds Fla So City of Live Oak Townsend So.2d Fla st DCA Jurors should be beyond even a suspicion of partiality OConnor State Fla Edwards adv Epstein Case No Memorandum of Law Page of23 Fla In Ortiz State So.2d Fla rd DCA the court stated the test for determining the competence of a juror is not whether a juror can control any bias or prejudice but rather whether he may lay aside those considerations Where there is any reasonable doubt the juror should be excused If a juror makes a statement sufficient to cause doubt as to his/her ability to render an impartial verdict the fact that trial judge or opposing counsel extracts conunitment that juror will be fair or try to be fair doesnt affect the need to excuse that juror for cause Price State So.2d Fla rd DCA Leon State supra Sikes Seaboard Coast Line Railroad Co So.2d Fla st DCA supra Longshore Fronrath Chevrolet So.2d Fla th DCA See also Fazzolari City of West Palm Beach So.2d Fla th DCA rev denied So.2d Fla in which the court stated that the jurors subsequent change in their answers arrived at after further questioning by appellees counsel must be viewed with some skepticism the assurance of a prospective juror that the juror can decide the case on the facts and the law is not determinative on the issue of a challenge for cause Juror is not impartial when one side must overcome a preconceived opinion of juror in order to prevail Hill State So.2d Fla Jan1es State So.2d Fla th DCA A juror should not serve if he or she is not indifferent to the action and should be excused for cause if there is a reasonable doubt as to the jurors ability to render an impartial verdict and if it is a close call the juror should be excused Somerville Ahuja M.D So.2d Fla Edwards adv Epstein Case No Memorandum of Law Page of23 th DCA Because impartiality of the finders of fact is an absolute prerequisite to our system of justice we have adhered to the proposition that close cases involving challenges to the impartiality of potential jurors should be resolved in favor of excusing the juror rather than leaving doubt as to impartiality Williams State So.2d Fla th DCA In Sydleman Benson So.2d Fla th DCA the court cautioned that the impartially of the finders of fact is an absolute prerequisite to our system of justice Close cases should be resolved in favor of excusing juror rather than leaving a doubt as to his or her impartiality Statements that establish grounds for cause a Will you have any difficulty in setting those negative feelings aside Pacot Wheeler So.2d Fla th DCA James State So.2d Fla th DCA Do you feel that my client is not starting out with a clean slate Overton State So.2d Fla Do you feel my client is not starting out on an even playing field Nash General Motors Corporation So.2d Fla rd DCA Is my client stai1ing out with a strike or half a strike against him Edwards adv Epstein Case No Memorandum of Law Page of23 Club West Inc Tropigas of Florida Inc So.2d Fla rd DCA Jaffe Applebaum So.2d Fla th DCA Is there a burden in your mind that my client has to overcome Goldenberg Regional Import and Export Tmcking Co Inc So.2d Fla th DCA Cumulative effect of comments require striking for cause if they raise a reasonable doubt as to ability to be impartial James State So.2d Fla rd DCA Juror should have been excused for cause where juror expressed distaste for lawyers suggested that he would hold the plaintiff to a clear and obvious standard of proof and indicated that plaintiffs in general were looking for easy money and trying to cheat the system to make an easy buck The juror also agreed that the plaintiff would have to overcome a resistance on his part ifhe served as a juror Frazier Wesch So.2d Fla DCA If there is any basis for a reasonable doubt as to whether a juror possesses that state of mind which will enable him to render an impaial verdict solely on the evidence submitted and the law announced at trial he should be excused for cause Ferias State So.2d Fla rd DCA Allowable areas of inquiry in rep01ied cases include matters affecting a prospective jurors personal life including a Whether he feels that verdicts will raise his insurance premiums Purdy Gulf Breeze Enterprises Inc So.2d Fla Edwards adv Epstein Case No Memorandum of Law Page of23 Whether or not he has formed or expressed an opinion on issues involved in a case based on newspaper aiticles and hearsay Singer State supra Whether or not they have negative attitude toward the legal system due to previous unfavorable experience with lawsuits filed against them or members of their family Levy Hawks Cav Inc So.2.d Fla rd DCA Whether or not they could consider the evidence and apply instruction of the court free from influence of what they have read or heard Smith State So.2d Fla th DCA Where the prospective juror vacillates between assertions of partiality and impaitiality a reasonable doubt has been created which would require that the juror be excused Plain State So.2d Fla st DCA Statement such as am a fair person and I think I could be fair are not sufficient to set aside impaitiality suggested by other responses Nash General Motors Corp So.2d Fla rd DCA It was reversible e1TOr for the trial court not to have excused for cause a juror who gave equivocal ai1swers about her husbands career and whether or not it would affect her ability to be impartial whether she would favor the State what weight she would give to police testimony ai1d where there was ai1 indication she misunderstood the burden of proof Jefferson State So.2d Fla rd DCA One of the most important principles governing challenges for cause recognizes that Edwards adv Epstein Case No Memorandum of Law Page of23 a juror is not impartial when one side must overcome preconceived opinion in order to prevail Price State So.2d Fla yct DCA Trotter State So.2d Fla sets out the procedural requirements for preserving a for-cause eITor Under Florida law to show reversible error a defendant must show that all peremptories had been exhausted and that an objectionable juror had to be accepted By this we mean the following Where a defendant seeks reversal based on a claim that he was wrongfully forced to exhaust his peremptory challenges he initially must identify a specific juror whom he otherwise would have struck peremptorily This juror must be an individual who actually sat on the jury and whom the defendant either challenged for cause or attempted to challenge peremptorily or otherwise objected to after his peremptory challenges had been exhausted Internal citations omitted II VACILLATION BY JUROR A juror should be excluded for cause when he or she has expressed reservations about either his/her pre-conceived opinions or his/her ability to be impartial even though the juror later attests that he or she could be fair Graham State So.2d Fla st DCA A juror should be excused who stated that she would not feel uncomfortable in telling her daughter or employer that she has rendered a big verdict against her daughters employer after previously indicating some misgivings about her ability to be fair Longshore Fronrath Chevrolet Inc So.2d at Fla th DCA In sh01i once the juror has expressed misgivings rehabilitation is not possible as one side must overcome a preconceived opinion of that juror in order to prevail Hill State So.2d Fla Edwards adv Epstein Case No Memorandum of Law Page of23 Where a juror initially demonstrates predilection in a case in which in the jurors mind would prevent him or her from impartially reaching a verdict a subsequent change in that opinion arrived at after further questioning by the parties attorneys or judge is properly viewed with some skepticism Club West Tropigas of Florida Inc So.2d Fla rd DCA The fact that the trial judge extracts a commitment from a prospective juror that he will try to be fair or even will be fair does not eliminate the prejudice or the grounds for the challenge Leon State supra Sikes Seaboard supra Robinson State So.2d Fla th DCA A trial courts structured questions which caused the juror to respond that he could be fair and impartial after declaring that he could not did not qualify to rehabilitate the juror He should have been struck for cause Straw Associated Doctors Health and Life So.2d Fla th DCA Answers to a trial courts leading questions should not be the sole factor for rehabilitating a potential juror Hagerman State So.2d Fla th DCA A potential jurors response to questions by the comt or counsel in an effo1t to rehabilitate him after having admitted to harboring some bias or prejudice that they can set aside those prior admitted feelings is not determinative of whether the juror should be excused for cause insofar as she responded that she did not think or believe that her bias would influence her which responses indicated she was not absolutely sure her bias would not affect her verdict A juror in a medical malpractice case against a cardiologist should have been excused after he stated that his bias probably would have an effect on his ability to render an impmtial verdict and that he was Edwards adv Epstein Case No Memorandum of Law Page of23 thinking if juror had not clarified answer that he would have held cardiologist to a lesser standard because plaintiff was a smoker she would have been struck for cause Somerville Abuja So.2d Fla th DCA While the Supreme Court recently explained that Florida law allows for the rehabilitation of jurors any such rehabilitation is limited to a prospective jurors lack of familiarity with or misinfonnation concerning the law Matan-anz State WL at Fla Sept Attempts to rehabilitate a juror with personal immutable opinions and attitudes and firmly held beliefs suggesting bias or prejudice remain prohibited Id Only oncems that stem from misinformation and confusion concerning the law or process are available for redress through rehabilitation Id I VOIR DIRE INQUIRY REGARDING LAW OR DEFENSES LAVADO STATE Counsel has the right to make an inquiry about a prospective jurors feelings about points oflaw or defenses specific to the case Lavado State So.2d Fla or whether the juror has feelings concerning issues arising in a case Singer State So.2d Fla Hill State So.2d Fla Lavado State The law on voir dire inquiry regarding defenses In Lavado State So.2d Fla rd DCA the district court ruled that the trial courts refi,sal to permit prospective jurors to be questioned on voir dire as to their ability to entertain a defense of voluntary intoxication was not an abuse of discretion where the trial court gave appropriate instructions on voltmtary intoxication and there was no showing that the jury having Edwards adv Epstein Case No Memorandum of Law Page of23 been sworn to follow those instructions failed to do so In a vigorous dissent Judge Pearson asserted that the district courts ruling was as wrong as it would have been had it approved a ruling which denied counsel the right to question prospective jurors altogether If he knew nothing else about the prospective jurors the single thing that defense counsel needed to know was whether the prospective jurors could fairly and impartially consider the defense of voluntary intoxication Despite this the majority approves a ruling which precluded counsel from asking the prospective jurors about their bias or prejudice against this defense Lavado So.2d at The Supreme Cou,1 agreed with Judge Pearson and reversed the district court with the observation that We can add nothing to Judge Pearsons comprehensive articulate and logical dissenting opinion and therefore adopt it in its entirety as our majority opinion Lavado State So.2d Fla Lavado State So.2d Supreme Court of Florida The trial judge refused to pennit the inquiry permitting only a general question regarding a prospective jurors ability to follow the courts instructions We can add nothing to Judge Pearsons comprehensive articulate and logical dissenting opinion and therefore adopt it in its entirety as our majority opinion Lavado State So.2d Fla rd DCA A meaningful voir dire must include questions about the jurors attitudes towards the defense The Florida Supreme Court in Lavado State So.2d Fla adopted the reasoning of the United States Supreme Courts ruling in Rosales-Lopez United States S.Ct which discussed the elements of a meaningful voir dire Edwards adv Epstein Case No Memorandum of Law Page of23 What is meaningful voir dire which will satisfy the constitutional imperative of a fair and impartial jury depends on the issues in the case to be tried The scope of voir dire therefore should be so varied and elaborated as the circumstances surrounding the juror under examination in relation to the case on trial would seem to require Thus where a jurors attitude about a paicular legal doctrine in the words of the trial court the law is essential to a determination of whether challenges for cause or peremptory challenges are to be made it is well settled that the scope of the voir dire properly includes questions about the references to that legal doctrine even if stated in the form of hypothetical questions Trial court may not preclude a party from inquiry during voir dire into bias bearing on a matter that is at the heart of the defendants case Igrassia State So.2d Fla th DCA Hypothetical questions are permitted provided they make a correct reference to the law that aid in dete1mining whether challenges for cause or preemptory challenges are proper Moore State So.2d Fla rd DCA IV INQUIRY ABOUT THE LEGAL SYSTEM AND FEELINGS ABOUT DAMAGES IN PERSONAL INJURY CASES Problems with the Legal System Levy Hawks Cay Inc So.2d Fla rd DCA stands for the proposition that when a negative attitude exists in a juror toward the legal system due to previous experiences with lawsuits the trial courts failure to challenge jurors for cause was reversible error When any reasonable doubt exists as to whether a juror possesses state of mind necessary to render an impartial verdict based solely Edwards adv Epstein Case No Memorandum of Law Page of23 on evidence submitted and law announced at trial he should be excused Personal Injury and Lawsuit and Damages In Sisto Aetna Casualty Surety Co So.2d Fla th DCA the court stated Without the opportunity to ask even a threshold question on the subject counsel for plaintiffs was unable to explore whether any given juror possessed a strong preconceived feeling or bias concerning personal injury lawsuits and the award of non economic damages such as pain and suffering If inquiry had been permitted and a prospective juror had expressed a definite bias against awarding intangible damages plaintiffs would have had a basis for requesting that the prospective juror be excused for cause depending on the exact questions asked and answers given See Goldenberg Regional Import Export Trucking Co So.2d Fla 4th DCA cf Fazzolari City of West Palm Beach So.2d Fla 4th DCA review denied So.2d Fla At the very least plaintiffs would have had the opportunity to explore the depth of the bias or the basis for the attitude in order to make a determination whether to exercise a peremptory or for cause challenge See Skiles Ryder Truck Lines Inc So.2d Fla 2nd DCA cert denied So.2d Fla In recent years the subject of non-economic damages has received widespread media attention It is a subject on which an individual may possess a strong bias or prejudice In a personal injury case where the issues of permanent injmy and past and future noneconomic damages are hotly contested allowing counsel to inquire about an individuals views on the sensitive area of non-economic damages is essential to a partys right to conduct a reasonable examination Our court has implicitly recognized that a prospective jurors attitude about personal injury lawsuits is an appropriate subject for inquiry See Fazzolari So.2d at Both liability and damages were hotly contested in this personal injury case It is ironic that while the trial court admonished the parties to limit their questions to those that would touch on the prospective jurors ability to be fair and impaial it then prevented questions that Edwards adv Epstein Case No Memorandum of Law Page of23 would have assisted both the trial court and the parties in making this detennination TIME ALLOWED TO CONDUCT VOIR DIRE The Court should not impose arbitrary time constraints on the Plaintiffs v01r dire examination of the venire as set forth below Florida Rule of Civil Procedure provides in part that the rights of the parties to conduct a reasonable examination of each juror orally shall be preserved Although a trial judge has considerable discretion in determining the extent of counsels examination of prospective jurors See Mendez State So.2d Fla th DCA the court may not impose arbitrary time limits on voir dire See Miller State So.2d Fla rd DCA In fact a court abuses its discretion when it unreasonably limits counsels ability to conduct a meaningful voir dire See Mendez at OHara State So.2d Fla th DCA Florida courts have held that it is an abuse of discretion for a trial court to impose on a party one-to-three minute time limits on questioning each prospective juror Gosha State So.2d Fla rd DCA The fact that a trial judge conducts an examination of jurors before turning the questioning over to counsel does not in and of itself justify arbitrary time limitation on counsels voir dire Carver Niedermayer So.2d Fla th DCA The purpose of voir dire is to obtain a fair and impartial jury to try the issues in Edwards adv Epstein Case No Memorandum of Law Page of23 the cause The time restrictions or limits on numbers of questions can result in the loss of this fundamental right Williams State So.2d Fla th DCA Attorney should be afforded ample time to elicit pertinent information from prospective jurors Ritter Jiminez So.2d Fla 3rd DCA Campbell State So.2d Fla th DCA While the trial judge has discretion it must be exercised so as not to violate the litigants right to a fair opportunity to make an intelligible and informed judgment as to the exercise of challenges Eastern Airlines Gellert So.2d Fla rd DCA VI FOR-CAUSE CHALLENGES MUST BE DECIDED BEFORE PEREMPTORY CHALLENGES ARE EXERCISED The Supreme Court reaffirms the importance of peremptory strikes and the procedure for preserving error Also there must be no reasonable doubt as to jurors fitness Equivocal answers can create reasonable doubt Kousho State So.2d Fla The Supreme Court established that the proper procedure for jury selection Challenges is deciding for-cause challenges before peremptories are exercised There must be enough qualified jurors available after challenges for cause are ruled upon so that all peremptories can be used and still have enough people left to seat a full jury Peremptories are to be used in an alternating fashion between plaintiff and defense Counsel objected to a system of selection that forced him to exercise peremptories before all valid causes had been granted and which required challenges be exorcised in the dark The court held the only fair scheme is to allow the parties to exercise their Edwards adv Epstein Case No Memorandum of Law Page of23 challenges singularly alternately and orally so that before a party exercises a peremptory challenge he has before him the full panel from which the challenge is to be made This leads to a second infirmity in the instant procedure After excusing one person for cause fifteen prospective jurors remained Allowing for six peremptories left nine jurors Only six however could serve There is no way that or could have served and as plaintiffs counsel pointed out they should have been excused After challenges for cause are made those excess persons over the number of needed jurors plus the number of allowable peremptories should be excused so that counsel may know who will serve if not excused Ter Keurst Miami Elevator Co So.2d Fla See also Tedder Video Electronics Inc So.2d Fla 2nd DCA Van Sickle James Zimmer M.D So.2d Fla 2nd DCA In dicta Justice Atkins of the Supreme Court made the following observations Many trial judges are developing ingenious plans to limit the time of jury selection in order to expedite cases and increase the case count for an individual circuit These judges are conscientious and well meaning but are allowing the disposition of cases to become more important than the administration of justice Unfortunately we contribute to this problem by demanding speedy trials and quick dete1minations so that the trial docket will flow as steadily as the crowds through Disney World But the comis are not businesses opened for the sale of merchandise or services In the trial of a case the jury selection and voir dire examination are just as critical to the outcome as the presentation of evidence Ter Keurst Miami Elevator Co So.2d Fla Negative feelings which are not party specific may create cause where there is a bias against general class of cases or issues Also there is a difference between I dont think it should and Edwards adv Epstein Case No Memorandum of Law Page of23 It wont or Id try not to or I would give it my best shot Answers such as I dont think it should Id try not to or Id give it my best shot are not good enough to say It wont influence me Four Wood Consulting LLC Fyne So.2d Fla th Somervillev Ahuja M.D So.2d Fla th DCA Additionally reasonable doubt is not overcome by a jurors silence as to a question asked of the entire panel Finally the fact that a juror may be trying to get off the jury does not change the need to excuse Four Wood Consulting LLC Fyne So.2d Fla th DCA A jurors admitting to feelings against personal injury cases to wit Believed in caps and thought suits increased insurance and cost of living He acknowledged it could influence him because it is part of his makeup then qualified the answer by saying It all depends on the evidence presented I dont have enough information about the case to understand whether or not my decision would be influenced The trial court denied a challenge for cause and the appellate court reversed Rodriguez Lagomasino So.2d Fla rd DCA The juror asserted that in EVERY slip and fall case the person who falls is at least partially responsible and that this would factor into his decision The trial corut denied the challenge for cause and the appellate court reversed Defense counsel e1Toneously convinced the trial judge to deny the challenge by arguing plaintiffs counsel had employed leading questions to get the answers and that the juror had later said he could be fair Algie Lennar Corporation So.2d Fla th DCA Edwards adv Epstein Case No Memorandum of Law Page of23 Even though the judge asks questions the lawyer can ask follow up questions The court noted Prospective jurors do not respond in the same manner to inquiry by the judge as they do to questions by counsel Miller State So.2d Fla rd DCA A juror must be excused for cause if they state they would tend to believe a witness police officer over a lay witness Suede State So.2d Fla th DCA Plaintiff can backstrike up to time the jury is sworn Lottimer North Broward Hospital District So.2d Fla th DCA Florida Statute says the qualifications of a juror in a criminal case shall be the same as their qualifications in a civil case The Florida Supreme Comi defines preponderance of the evidence and uses the greater weight of the evidence OR evidence which more likely than not tends to prove an issue Gross Lyons So.2d Fla INDEX OF CASES SUMMARY OF LAW REGARDING CHALLENGES FOR CAUSE Fla Civ Algie Lennar Corp So.2d Fla 4tli DCA Auriemme State So.2d Fla th DCA Campbell State So.2d Fla 4tl DCA Carver Niedermayer So.2d Fla 4tl DCA City of Live Oak v.Townsend So.2d Fla st DCA Edwards adv Epstein Case No Memorandum of Law Page of23 Club West Inc Tropigas of Florida Inc So.2d Fla rd DCA Disla Blanco WL Fla 4th DCA Nov Eastern Airlines Gelle1i So.2d Fla rd DCA Farias State So.2d Fla rd DCA Fazzolari City of West Palm Beach So.2d Fla th DCA Four Wood Consulting LLC Fyne So.2d Fla th DCA Franqui State So.2d Frazierv Wesch So.2d Fla th DCA Goldenberg Regional Impo1t and Export Trucking Co Inc So.2d Fla th DCA Gosha State So.2d Fla yd DCA Graham State So.2d Fla st DCA Gross Lyons So 2d Fla Hagerman State So.2d Fla th DCA Hill State So.2d Fla Igrassia State So.2d Fla th DCA Jaffee Applebaum So.2d Fla 4tl DCA James State So.2d Fla rd DCA James State So.2d Fla th DCA Jefferson State So.2d Fla rd DCA Johnson Reynolds Fla So Edwards adv Epstein Case No Memorandum of Law Page of23 Juede State So.2d Fla th DCA Kearse State So.2d Fla Kopsho State So.2d Fla Lavado State So.2d Fla rd DCA Lavado State So.2d Fla Leon State So.2d Fla rd DCA Lewis State So.2d Fla th DCA Levy Hawks Owl Inc So.2d Fla rd DCA Longshore Fronrath Chevrolet So.2d Fla th DCA Lottimer North Broward Hospital District So.2d Fla th DCA Lusk State So.2d Fla Matan-anz State WL Fla Sept Mendez State So.2d Fla th DCA Miller State So.2d Fla rd DCA Moore State So.2d Fla rd DCA Nash General Motors Corporation So.2d Fla rd DCA OConnor State Fla OHara State So.2d Fla th DCA Olive State Fla So Ortiz State So.2d Fla rd DCA Overton State So.2d Fla Edwards adv Epstein Case No Memorandum of Law Page of23 Pacot Wheeler So.2d Fla.Ah DCA Plair State.453 So.2d Fla st DCA Price State So.2d Fla rd DCA Purdy Gulf Breeze Enterprises Inc So.2d Fla Ritter Jimenez So.2d Fla rd DCA Robinson State So.2d Fla DCA Rodriguez Lagomasino So.2d Fla yct DCA Rosales-Lopezv United States,451 Sikes Seaboard Coast Line Railroad Co So.2d Fla DCA Singer State So.2d Fla Sisto Aetna Casualty Surety Co So.2d Fla th DCA Skiles Ryder Truck Lines Inc So.2d Fla nd DCA Smith State So.2d Fla th DCA Somerville Abuja So.2d Fla DCA Straw Associated Doctors Health and Life So.2d Fla DCA Sydleman Benson So.2d Fla DCA Tedder Video Electronics Inc So 2d Fla nd DCA Ter Keurst Miami Elevator Co So.2d Fla Trotter State So.2d Fla Edwards adv Epstein Case No Memorandum of Law Page of23 Van Sickle James Zimmer MD So.2d Fla i Williams State So.2d Fla 5tl DCA Williams State So.2d Fla th DCA I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this day of-4 ne Mail jsx searcylaw.com and nn searcylaw.com ary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Memorandum of Law Page of23 Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Kara Berard Rockenbach Esquire kara linkrocklaw.com tbermudez flacivillaw.com Link Rockenbach P.A Palm Beach Lakes Blvd Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Scott Link Esquire Scott linkrocklaw.com Tina linkrocklaw.com Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Edwards adv Epstein Case No Memorandum of Law Page of23 Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein 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 qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 10Cy rq YY C?J?yO c/XE?lgF GM??H p?ݡG Dp9Oh CTX CTX CJ4 I J6 CJ4 CK qrrM?q qq 9/CX?o CX qYqr rC dd?Z c6S ttcx A CTX CTX 10Cy rq rqYY X?qiX:4 3J Db ZH uD-8 1g?BH I vS 7Oo7u E?K?O J6 UJP U0 UT??ʴ UT UT UT O(p U(u UF1 iZ qr?r CX CX Yr zKW:E A K5M P-M UW VW L1J KJ56 N/Q SQ rC 6J ߵl ߵl 5TZ w8ĥDG oj?K _4 N)?Y Hp pRqc?W26 vz?WBrz?ZB??3X H4 CTX A CTX X4 U5 P8 5D qr qr 10Cy qr YY Mo?ANp D01jJ 9F bzEV 4O 8V CTX O!o CTX KK AA qr A C5 qr rYY 1A?CC V9 a c?F CTX A G5 qr EeD?M CTX 9?rY 10Cy rq qY ȠX1 a f??B CTX 9F I CTX 6D N?qr rrqq qC O?J RmA??b"0 M?.F q?D B?G CTX CTX F4 d6P A F4 qr rYY 4G AV8 CTX UY UL0 U0 U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8
