At the previously held Summary Judgment hearing this Court deferred oral argument on the issue of probable cause focusing on the applicability of the litigation privilege to Edwards claim for malicious prosecution due to the then recently published decision in Wolfe Foreman So 3d Fla 3d DCA A determination that probable cause existed to file suit as a matter of law would prevent a time-consuming and costly trial for which there is no legal basis SUMMARY OF THE ARGUMENT Summary Judgment should be entered in favor of Epstein on Edwards cause of action for Malicious Prosecution Edwards has not and will never be able to prove a want of probable cause as the undisputed facts delineated below irrefutably establish that there was probable cause as a matter of law at the time Epstein filed his Complaint Accordingly Epstein is entitled to judgment as a matter of law STATEMENT OF UNDISPUTED FACTS In November it became national news that Defendant Scott Rothstein Rothstein a law partner of Defendant/Counter-Plaintiff Bradley Edwards fled to Morocco to evade criminal prosecution for using their law firm Rothstein Rosenfeldt Adler RRA to perpetrate a massive Ponzi scheme It was widely reported that RRA Rothstein Rothstein partners and other co conspirators whose identities had not yet been determined defrauded investors into purchasing fake settlements of cases purportedly being litigated at RRA See Affidavit of Jeffrey Epstein filed in support of this Motion hereinafter Epstein Affidavit Amended Complaint in Razorback Funding LLC et al Scott Rothstein et al Case No Deposition Transcript of Bradley Edwards dated March Deposition Transcripts of Scott Rothstein in In re Rothstein Rosenfeldt Adler PA and Razorback Funding LLC et al Scott Rothstein et al Case No Deposition Transcript of Jeffrey Epstein Rothstein Tonja Haddad P.A SE 7th Street Fort Lauderdale FL returned to South Florida a short time later to face federal criminal charges and civil claims brought by private investors arising out of what was reported to be a Billion Ponzi scheme the largest in Floridas history the Ponzi Scheme See Epstein Affidavit Infonnation Charging Scott Rothstein in United States of America Scott Rothstein Epsteins Answer and Affirmative Defenses to Edwards Fourth Amended Counterclaim Deposition Transcripts of Scott Rothstein in In re Rothstein Rosenfeldt Adler PA and Razorback Funding LLC et al Scott Rothstein et al Case No On December the Federal Government filed a thirty-six page Information against Rothstein charging that RRA of which Edwards was then a partner was a racketeering Enterprise and that Rothstein and his partners at RRA as well as other unidentified co conspirators used RRA to defraud investors out of Billion by inducing them to invest in bogus settlements of alleged RRA cases the Rothstein Information See Epstein Affidavit Infonnation Charging Scott Rothstein in United States of America Scott Rothstein The Rothstein Information asserted that Rothstein his partners at RRA and his yet unidentified co-conspirators engaged in multiple felonious acts and were able to lure investors into their Ponzi scheme by fraudulent advising potential investors of fabricated lawsuits in which they falsely claimed there were confidential settlement agreements ranging in value from hundreds of thousands of dollars to millions of dollars available for purchase at a discounted rate It further alleged that Rothstein and his other unnamed co-conspirators utilized the offices of RRA to convince potential investors of the legitimacy of these fabricated settlements and the success of the law firm which enhanced the apparent credibility of the purported investment opportunities in the Ponzi Scheme and utilized funds obtained through the fraudulent Ponzi Scheme to supplement and support the operation and activities of RRA to expand RRA by hiring additional attorneys Tonja Haddad P.A SE 7th Street Fort Lauderdale FL and support staff to fund salaries and bonuses and to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA criminal Enterprise See Infonnation Charging Scott Rothstein in United States of America Scott Rothstein Scott Rothstein admitted to and was convicted for the fraudulent scheme perpetrated at RRA He is serving a year sentence See Infonnation Charging Scott Rothstein in United States of America Scott Rothstein Plea Agreement between United States of America and Scott Rothstein Epstein also became aware of news reports that Rothstein was disbarred and that the Florida Bar was actively investigating at least half of the attorneys employed by RRA in connection with the Ponzi Scheme See Epstein Affidavit See also e.g Miami Herald Scott Rothstein Scandal Scott Rothstein Partners Probed January The Florida Bar is investigating at least former senior lawyers in the now-bankrupt Fort Lauderdale law firm headed by Scott Rothstein who was disbarred before he was criminally charged last month with using the firm to run a billion investment racket On November the law firm of Conrad Scherer initiated a lawsuit against Rothstein and others Razorback Funding LLC et al Scott Rothstein et al Case No hereinafter referenced as the Razorback Complaint for the fraudulent scheme perpetrated at RRA involving among other deceptive practices RRA efforts to perpetuate the Ponzi Scheme through the use of fraudulent discovery and pleadings in the cases RRA through Edwards was litigating against Epstein During the time of the Ponzi Scheme RRA was in fact prosecuting three civil cases against Epstein the Epstein Cases through lead counsel Brad Edwards See pleadings in LM Jeffrey Epstein AB EW Jeffrey Tonja Haddad P.A SE 7th Street Fort Lauderdale FL Epstein AB and Jane Doe Jeffrey Epstein Marra/Johnson Deposition Transcript of Jeffrey Epstein line line The Razorback Complaint specifically avowed that such fraudulent discovery and pleadings in the Epstein Cases were being used by RRA to overinflate the supposed monetary value of the Epstein Cases and to attempt to legitimize the false claims made to potential investors i.e that Epstein was willing to pay hundreds of millions of dollars in settlements to additional fictional plaintiffs in fabricated RRA cases to avoid what RRA claimed would be devastating publicity about Epstein and the world famous celebrities politicians and other dignitaries associated with him See Epstein Affidavit Razorback Complaint Specifically the Razorback Complaint stated purported settlements albeit fraudulent were based on actual cases being handled by RRA For example one of the settlements involved herein was based upon facts surrounding Jeffrey Epstein the infamous billionaire financier Representatives of D3 were offered the opportunity to invest in a pre-suit court settlement against Epstein involving a different underage female plaintiff See Razorback Complaint The female described in the Razorback Complaint was not an actual client of RRA and there was in fact no such pre-suit court settlement The Razorback Complaint further provided To augment his concocted story Rothstein invited D3 to his office to view the thirteen bankers boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real See Razorback Complaint The Razorback Complaint further alleged that Rothstein falsely told investors that his team of investigators uncovered high profile celebrities dignitaries and international figures onboard Epsteins private jet In order to corroborate the claims that such high-profile persons were implicated in the Epstein scandal Rothstein showed D3 copies of a flight log purportedly containing names of celebrities dignitaries and international figures See Razorback Complaint Additionally the Razorback Complaint asserted that Rothstein exploited Tonja Haddad P.A SE 7th Street Fort Lauderdale FL RRAs representation in the Epstein Cases to fraudulently pursue issues and evidence unrelated to the underlying litigation but which was potentially beneficial to lure investors into the Ponzi scheme including discovery to obtain information and documentation of famous individuals who at some point in time may have flown on Epsteins plane and noticing the depositions of celebrities that had no involvement in the specific claims of Edwards clients See Razorback Complaint In fact none of the alleged conduct for which Edwards three clients in the Epstein Cases sought recovery was alleged in the Epstein Cases to take place on or otherwise involve Epsteins aircraft or a single celebrity politician or dignitary associated with Epstein See pleadings in LM Jeffrey Epstein AB EW Jeffrey Epstein AB and Jane Doe Jeffrey Epstein Marra/Johnson According to the defrauded investors in the Razorback Complaint the fraudulent pleadings and discovery on behalf of Edwards three clients in the Epstein Cases were deliberately crafted to present a salacious sexually charged tale of explosive facts that would convince investors to believe the false claims urgently made to investors that Epstein had allegedly offered for settlement of the claims held by various young women who were his victims See Razorback Complaint The fraudulent discovery in the Epstein Cases that the Razorback Complaint declared took place solely to further the Ponzi Scheme at RRA did in fact take place This discovery was conducted by Plaintiff Edwards Rothsteins partner at RRA and the lead attorney in charge of the Epstein cases During the time in question Edwards himself personally pursued discovery in the Epstein Edwards was a partner at Rothstein Rosenfeld Adler RRA from April through November which was during the same period when according to the Razorback Complaint the fraudulent pleadings and discovery were used to perpetuate the Ponzi Scheme See Deposition Transcript of Bradley Edwards dated March Deposition Transcripts of Scott Rothstein in In re Rothstein Rosenfeldt Adler PA and Razorback Funding LLC et al Scott Rothstein et al Case No I Tonja Haddad P.A SE 7th Street Fort Lauderdale FL Cases to identify the celebrities politicians and dignitaries associated with Epstein who flew on Epsteins plane and noticed for deposition various famous dignitaries and celebrities such as Bill Clinton and David Copperfield Edwards pursued this discovery knowing that his clients made no allegations of improper conduct against them taking place on Epsteins planes or implicating any celebrities politicians or dignitaries See letter dated July from Edwards attached as Exhibit to his deposition of March dockets and pleadings in LM Jeffrey Epstein AB EW Jeffrey Epstein AB LM Jeffrey Epstein Marra/Johnson and Jane Doe Jeffrey Epstein Marra/Johnson copies of subpoenas Deposition Transcript of Jeffrey Epstein line line Initial Complaint filed by Epstein dated December pages Razorback Amended Complaint pp While he was a partner at RRA and in the height of the Ponzi Scheme on July Edwards filed a two hundred thirty four page one hundred fifty-six count federal complaint against Epstein on behalf of the same plaintiff for whom there was already a lawsuit pending in state court a case that Edwards had been prosecuting against Epstein for the better part of a year See LM Jeffrey Epstein Marra/Johnson Deposition Transcript of Jeffrey Epstein line line LM Jeffrey Epstein AB The federal complaint signed by Edwards himself was based on the same allegations made in the complaint filed by Edwards in the state case but the allegations were highly sensationalized in the federal complaint For example the federal complaint alleged that a LM was identified by the FBI and U.S Attorneys office in a criminal investigation against Epstein However LM was not on the FBls or the U.S Attorneys list referenced in paragraph of the Complaint Epstein coerced or forced the then-minor L.M to perform oral sex on him However in her September deposition LM testified under oath at page that she never had oral sex with Epstein Tonja Haddad P.A SE 7th Street Fort Lauderdale FL Epstein knowingly transported LM and other minors in interstate commerce with the intent that the sic LM engage in prostitution However in her February deposition LM testified under oath at page she never traveled with Epstein See L.M Federal Complaint Epsteins Motion to Dismiss Complaint and Incorporated Memorandum of Law Jl in LM Jeffrey Epstein Marra/Johnson Consistent with its purpose as a prop to show investors in the Ponzi Scheme which collapsed only a few months later Edwards filed the complaint in federal court but never served it on Epstein and never prosecuted it.2 In another of the Epstein Cases that the Razorback Complaint proclaimed was fraudulent touted to investors in the Ponzi Scheme Edwards filed a motion in which he requested that the Court order Epstein to post a fifteen million dollar bond See Jane Doe Jeffrey Epstein Marra/Johnson See Razorback Funding LLC et al Scott Rothstein et al Case No The court in reviewing this motion confirmed that there was no legitimate basis for Edwards to file it calling it devoid of evidence See Order in Jane Doe No Epstein Dated November In this motion Edwards not only described at length Epsteins net worth but also filed supplemental papers that listed in great detail Epsteins personal belongings including his vehicles planes and other items of substantial value all at the time when the Epstein Cases were the lynchpin to keeping the Ponzi Scheme from unraveling See Jane Doe Jeffrey Epstein Marra/Johnson Epstein Affidavit Razorback Complaint Depositions taken of Scott Rothstein in In re Rothstein Rosenfeldt Adler PA Additionally on September when according to the reports and Rothstein himself the need for new investor money in the Ponzi Scheme was becoming dire Edwards instructed his assistant at RRA to review and prepare for filing a complaint in Federal Court similar to the one we did for LM See email dated September from Brad Edwards to Beth Williamson This complaint was to be filed on behalf of EW another of Edwards clients in the Epstein Cases for whom he also had been litigating a state court case for almost a year arising out of the same alleged facts Edwards gave these instructions to his assistant two months after filing the federal complaint against LM that he neither served on nor prosecuted against Epstein Tonja Haddad P.A SE 7th Street Fort Lauderdale FL The Razorback Complaints detailed synopsis of the massive fraud that occurred with and in the Epstein Cases Edwards filing of a federal complaint while a state complaint arising out of the same matters was already pending on behalf of Edwards same client Edwardss discovery practice and bond motion in the Epstein Cases during the time in question that corroborated the claims about the Epstein Cases made in the Razorback Complaint Rothsteins Indictment and the repeated statements in the Rothstein Information regarding Rothstein unidentified partners and co-conspirators at RRA who were under investigation by the federal government as well as the Florida Bar and the countless media reports daily unveiling the further extent of RRA fraudulent conduct were the facts upon which Epstein relied in filing suit against Rothstein as the front man of the Ponzi Scheme and against Edwards Rothstein partner at RRA and the lead attorney responsible for what investors in the Razorback Complaint confirmed was fraudulent activity in the Epstein Cases used to perpetuate the Ponzi Scheme The undisputed facts set forth herein were the same facts alleged in Epsteins second amended complaint were determined by the Court to have stated a cause of action for abuse of process and survived Edwards motion to dismiss See Order on Motion to Dismiss Plaintiffs Second Amended Complaint dated October PROCEDURAL HISTORY In its May order granting Epsteins motion for Summary Judgment this Court recounted the following procedural history with respect to Epsteins suit Epstein filed suit against Edwards Edwards then filed a counter-claim against Epstein Epstein subsequently dismissed his Complaint without prejudice The counter-claim proceeded undergoing several amendments As it now stands the Fourth Amended Counterclaim has two causes of action abuse of process and malicious prosecution Epstein moved for summary judgment arguing that the litigation privilege applies to both the abuse of process and malicious prosecution claims See Order Granting Epsteins Motion for Summary Judgment While Epstein had asserted other Tonja Haddad P.A SE 7th Street Fort Lauderdale FL grounds upon which he relied in support of his Motion the court directed the parties to only address the litigation privilege issue The Court entered its written order granting Summary Judgment in favor of Epstein solely upon application of the litigation privilege as required by the then binding precedent of Wolfe Foreman So 3d Fla 3d DCA Final Judgment was thereafter entered in favor of Epstein Edwards appealed the judgment as it pertained to his malicious prosecution action during which time the Fourth District issued Fischer Debrincat So 3d Fla 4th DCA holding that the litigation privilege did not apply to a malicious prosecution action and certifying to the Supreme Court of Florida conflict with Wolfe The Fourth District Court of Appeal reversed this Courts decision based upon Fischer and again certified conflict Edwards Epstein So 3d Fla 4th DCA Epstein filed for review in the Supreme Court The Supreme Court resolved the conflict in Debrincat Fischer No WL Fla Feb holding that the litigation privilege does not bar a malicious prosecution action where all of the elements to support such a claim are met Based upon Debrincat the Supreme Court declined to review the decision of the Fourth District Court of Appeal in this case Upon remand by Fourth District Court of Appeal and as permitted by law Epstein renews his Motion for Summary Judgment based on the critical failure of Edwards to establish a want of probable cause for Epsteins suit against Edwards The material undisputed facts in this case coupled with the applicable law germane thereto demonstrate that Summary Judgment in favor of Epstein on this issue is mandated STANDARD FOR SUMMARY JUDGMENT Summary judgment is proper if there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law Volusia County Aberdeen at Ormond Beach Tonja Haddad P.A SE 7th Street Fort Lauderdale FL So 2d Fla Smith Shelton So 2d Fla 4th DCA It is mandated when the pleadings depositions answers to interrogatories admissions affidavits and other materials in evidence on file show that there are no genuine issues as to any material fact and that the moving party is entitled to judgment as a matter of law FLA R.CIV When an appellate court enters a reversal of summary judgment and remands the case for further proceedings it is proper for trial court to again consider a motion for summary judgment if such should be presented Pan-American Life Ins Co Tunon So 2d Fla 3d DCA See also Const Co of Ohio Inc Rinker Materials Corp So 2d Fla 4th DCA filing of further motions for summary judgment are permissible if it could be clearly demonstrated there was no genuine issues of fact remaining It is also preferred if as is true in this case consideration of a motion for summary judgment would be in the best interests of the parties and the public inasmuch as it would avoid needless expense and conserve precious judicial resources Walker Atlantic Coast Line Railroad Co So 2d Fla 1st DCA Here the undisputed and incontrovertible facts establish that Edwards has not and cannot as a matter of law prove that there was an absence of probable cause for Epstein to file suit against Edwards As this is a critical element of Edwards Malicious Prosecution cause of action against Epstein the inability to establish it as a matter oflaw mandates Summary Judgment in Epsteins favor SUMMARY JUDGMENT MUST BE GRANTED WHEN SUFFICIENT PROBABLE CAUSE EXISTED AT THE TIME EPSTEIN FILED SUIT AGAINST EDWARDS In Florida an action for malicious prosecution is a serious matter Cent Fla Mach Co Inc Williams So 2d Fla 2d DCA Malicious prosecution actions are not generally favored in Florida Id at A malicious prosecution action requires that a plaintiff prove each of the following six elements a criminal or civil judicial proceeding was commenced against the plaintiff the proceeding was instigated by the defendant in the Tonja Haddad P.A SE 7th Street Fort Lauderdale FL malicious prosecution action the proceeding ended in the plaintiffs favor the proceeding was instigated with malice the defendant lacked probable cause and the plaintiff was damaged See Doss Bank of America N.A So 2d Fla 5th DCA Kalt Dollar Rent-A-Car So 2d Fla 3d DCA holding that the absence of any one of these elements will defeat a malicious prosecution action emphasis added Adams Whitfield So 2d Fla Alamo Rent-A-Car Inc Mancusi So 2d Fla The fifth element the absence of probable cause is the element that as a matter of law Edwards cannot prove warranting Summary Judgment In Goldstein Sabella So 2d Fla the Supreme Court of Florida explained the meaning of probable cause in the context of a malicious prosecution action as follows Probable cause is defined as A reasonable ground of suspicion supported by circumstances sufficiently strong in themselves to warrant a cautious man in the belief that the person accused is guilty of the offense with which he is charged Dunnavant State Fla So 2d Fla This as well as other acceptable definitions of the term indicates that one need not be certain of the outcome of a criminal or civil proceeding to have probable cause for instituting such an action Id at Probable cause in the context of a civil suit is measured by a lesser standard than in a criminal suit Wright Yurko So 2d Fla 5th DCA The standard for establishing probable cause in a civil action is extremely low and easily satisfied Gill Kostroff F.Supp 2d M.D Fla Even in the criminal context such as when analyzing probable cause to support a search warrant probable cause can be inferred from the facts See State Powers So 2d Fla 4th DCA Under the higher standard for finding probable cause in the criminal context it is well settled that probable cause must be judged by the facts that existed at the time of the defendants arrest not evidence subsequently learned or provided to the prosecution Mailly Jenne So Tonja Haddad P.A SE 7th Street Fort Lauderdale FL 2d Fla 4th DCA Probable cause is judged by the facts and legal state of affairs that existed at the time of the arrest Fla Game Freshwater Fish Commn Dockery So 2d Fla 1st DCA Hindsight should not be used to determine whether a prior arrest or search was made with probable cause Events that occur subsequent to the arrest cannot remove the probable cause that existed at the time of the arrest citations omitted McCoy State So 2d Fla 2d DCA holding that hindsight should not be used to determine whether a prior arrest or search was made with probable cause Dodds State So 2d Fla 4th DCA holding that events that occur subsequent to the arrest cannot remove the probable cause that existed at the time of the arrest The same principle requiring that the existence of probable cause be determined at the time suit is commenced applies in a malicious prosecution case See Gill Kostroff F.Supp 2d M.D Fla A determination of whether probable cause exists is based on the facts known by the defendant in the malicious prosecution action at the time the underlying action was initiated not some later point in time applying Florida law see also Fee Parker Lloyd P.A So 2d at We find the facts within Mr Parkers knowledge at the time suit was filed sufficient to constitute probable cause for the commencement of the malpractice action Florida Standard Jury Instruction Probable cause means that at the time of instituting or continuing a criminal civil proceeding against another the facts and circumstances known to defendant other person were sufficiently strong to support a reasonable belief that claimant had committed a criminal offense the claim proceeding was supported by existing facts The law is clear that courts must only look to the facts within the Plaintiffs knowledge at the time suit was filed to determine if they were sufficient to satisfy extremely low threshold of probable cause for the commencement of the lawsuit Fee Parker Lloyd P.A Tonja Haddad P.A SE 7th Street Fort Lauderdale FL Sullivan So 2d Fla 4th DCA However while the time frame to which the courts must look to determine the existence of probable cause is the same the standard for satisfying probable cause is much lower in a civil case than in a criminal case In the case at bench at the time Epstein filed suit against Edwards and Rothstein Edwards was a partner at RRA and the lead attorney on the cases being prosecuted by RRA against Epstein As a result of widely distributed media reports,3 and criminal and civil case filings it was a matter of public knowledge that RRA was operating as a front for a Billion Ponzi Scheme in which real RRA cases were being used to defraud investors The cases Edwards was prosecuting against Epstein had undeniably been used to defraud investors in the RRA Ponzi Scheme See Information Charging Scott Rothstein in United States of America Scott Rothstein Epsteins Answer and Affirmative Defenses to Edwardss Fourth Amended Counterclaim Deposition Transcripts of Scott Rothstein in In re Rothstein Rosenfeldt Adler PA and Razorback Funding LLC et al Scott Rothstein et al Case No Multi-million dollar lawsuits regarding the Ponzi Scheme filed against RRA Rothstein and others contained detailed allegations of fraudulently prepared documents and discovery from the Epstein Cases that were shown to investors to lure them into the Ponzi Scheme See Razorback Amended Complaint pp CjCj These are the very same cases that Edwards was then litigating against Epstein at the same time that the federal government and defrauded investors asserted that RRA through its agents and their co-conspirators was operating the Ponzi Scheme Furthermore the Information filed against Scott Rothstein by the Federal government repeatedly references RRA as the Enterprise with which Rothstein and his co-conspirators were In fact one could not read a newspaper or turn on the television without hearing about RRA and the Ponzi Scheme for several months Tonja Haddad P.A SE 7th Street Fort Lauderdale FL associated and by which they were employed The Rothstein Information charged that Rothstein and his conspirators known and unknown participated in or conspired to participate in racketeering activity to further the Ponzi scheme at RRA See Infonnation charging Scott Rothstein This coupled with Edwards being the lead attorney responsible for the very same Epstein Cases which the investors in the Razorback Complaint alleged were utilized to defraud them in the Ponzi Scheme created sufficient cause for Epstein to file suit Moreover as delineated in the statement of undisputed facts above at the same time that the Ponzi Scheme was in dire need of funding to keep it alive Edwards filed a Federal case against Epstein on behalf of the same plaintiff for whom Edwards was already litigating a case based on the same matters in state court See LM Jeffrey Epstein Marra/Johnson and LM Jeffrey Epstein AB However the facts delineated in the federal complaint were embellished and included deceitful allegations thereby making the federal complaint a more effective tool to enhance the apparent value of the Epstein Cases which the investors alleged in the Razorback Complaint were fraudulently used to lure them into the Ponzi Scheme See Epsteins Motion to Dismiss Complaint and Incorporated Memorandum of Law fl4 in LM Jeffrey Epstein Marra/Johnson Edwards neither served the federal complaint nor prosecuted it against Epstein corroborating the logical conclusion that it was filed solely to further the Ponzi Scheme Moreover while he was a partner at the law firm that the federal government asserted was a criminal Enterprise and consistent with the allegations in the Razorback Complaint Edwards also conducted questionable discovery and filed an unsupportable bond motion for millions of dollars against Epstein detailing Epsteins financial net worth in Federal court during the exact time the cases were being shown to the investors See Statement of Undisputed Facts above Tonja Haddad P.A SE 7th Street Fort Lauderdale FL The foregoing incontrovertible facts the facts known to Epstein at the time the underlying action was initiated satisfy the extremely low threshold of probable cause required to defeat a malicious prosecution claim See Wright Yurko So 2d Fla 5th DCA Accordingly Epstein is entitled to judgment because Edwards cannot as a matter of law establish an absence of probable cause which is an indispensable element of Edwards cause of action against Epstein for malicious prosecution Thompson McKinnon Securities Inc Light So 2d Fla 3d DCA CONCLUSION Summary Judgment must be granted in favor of Epstein because there is no material dispute as to any of the numerous facts demonstrating as a matter of law that Probable Cause existed at the time Epstein filed suit Accordingly in reliance upon the foregoing arguments and authorities Plaintiff/Counter-Defendant Jeffrey Epstein respectfully requests that the Court grant his Motion for Summary Judgment WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties on the attached service list this June Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street Suite Fort Lauderdale Florida facsimile Tonja TonjaHaddad.com SERVICE LIST CASE NO Tonja Haddad P.A SE 7th Street Fort Lauderdale FL Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe eissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com SE th Street Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Tonja Haddad P.A SE 7th Street Fort Lauderdale FL 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 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