EFTA00619848.pdf

3 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PAU., BEACH COUNTY, FLORIDA CASE NO.502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. COWARDS, individually, Defendants. HEARING BEFORE THE HONORABLE JUDGE DAVID CROW Monday, February d, 2013 (14) 9:01 a.m. - 9:1B a.m. Palm Beach County Courthouse, Courtroom 9C ( is ) 205 North Dixie Highway Palm Beach County, Florida (16) Stenographically Reported By: Sara Storey, FPR Florida Professional Reporter APPEARANCES: On behalf of the Plaintiff: ( 3) Tonja Haddad. P.A. (6) (7) (8I 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) 25) BY: TONJA HADDAD. ESQUIRE On behalf of the Defendants: Searcy. Denney. Scarola, et al. BY: JACK SCAROLA, ESQUIRE 2 (17) (18) (19) (20) (21) (22) (23) (24) (25) (1) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) (22) (23) (24) (25) PROCEEDINGS MS. COLEMAN: Excuse me one moment. I'm sorry. The fast page of that notebook I need to take out. Can I just grab my -- they're my notes. THE COURT: I can't read your notes? MS. COLEMAN: Well, I wouldn't want to give you my notes without giving a copy to Mr. Scarola, because that would be inappropriate. Good morning, Judge. Tonja Haddad -- THE COURT: Let me just stop you and ask you, is this something I can do on an 8:45. it seems like a lot? MS. COLEMAN: No. Your Honor, it's not. THE COURT: Okay. MS. COLEMAN: It is my motion on behalf of Mr. Epstein. And since the date it was filed I have sent repeated requests to Mr. Scarola's office asking for a specially set date upon which he was available to argue our motion. THE COURT: All right. MS. COLEMAN: Mr. Scarola refused to provide us dates and instead unilaterally set it before this court today. What was originally set before this court today was an issue related to our 4 discovery which I think would be more germane to the issues since you denied our protective order last Thursday. There is no way this can be heard in five minutes without belaboring the point. And we would respectfully request that since Mr. Scarola's office is not cooperating that you would provide a specially-set date upon which we can argue our Motion to Dismiss in a corporated memorandum of law. MR. SCAROLA: May I have my five minutes to convince you otherwise? THE COURT: Let me just say, I generally don't give dates for counsel. I don't get involved in scheduling. What I generally do is say you schedule it within a certain period of time, if you don't I'll schedule it. But Yes, sir. MR. SCAROLA: Thank you. May I approach the bench? THE COURT: Yes, sir. MR. SCAROLA: Thank you. Your Honor, this is our fourth amended complaint And the fourth amended complaint makes two changes from the third amended complaint which was the subject of multiple challenges all of which were denied. Those two changes appear in the 1 (Pages 1 to 4) WWW.USLEGALSUPPORT.COM EFTA00619848 5 7 (1 ) wherefore clause as to count one, and the wherefore (1) hearing? (2 ) clause as to count two. Both of the changes are (2 ) THE COURT: Well. I'll tell you what I'm going (3 ) identical. The prior complaint said that we (3) to do. I'm going to look at it. so if you want to. ( 4) reserved leave to assert a claim for punitive (4 ) you know -- ( 5) damages upon satisfying the statutory (5) MS. COLEMAN: Then I will — (6 ) prerequisites. The amendment says (6 ) THE COURT: Go ahead. ( 7) counter-plaintiff Edwards, having satisfied the (7 ) MS. COLEMAN: Go ahead. I'm sorry. ( 8) statutory prerequisites for the assertion of a (8 ) THE COURT: We got more than five minutes. ( 9) claim for punitive damages and having been granted (9) MS. COLEMAN: My position is as follows. 10 ) leave of court to assert such a claim does hereby (10) respectfully Mr. Scarola's opinion is just that. 11 ) also assert a claim for punitive damages. The (11) His opinion of course of his complaint is that it's 12 ) factual allegations of this complaint remain ( 12) fine, there is nothing wrong. Our position is in 13 ) absolutely unchanged from the repeatedly. ( 13) drast contravention to Mr. Scarola's opinion. The 14 ) unsuccessfully challenged third amended complaint. ( 14) law, in ow opinion, and as proved by our 15 ) The Motion to Dismiss before Your Honor is ( 15) voluminous notebook with which you've been 16 ) nothing more than a motion for a reconsideration of ( 16) provided -- and for the record, we've provided over 17 ) Your Honor's having granted the leave to assert a ( 17) two hundred pages of documentation to Judge Crow in 18) claim for punitive damages. And the concept that ( 18) support of our Motion to Dismiss. The legal 19) it is necessary after having satisfied the ( 19) standard for pleading punitive damages under note 20) statutory prerequisites to again argue all of the (20) 1-- I'm sorry. I completely lost the paper that I 21 ) same legal issues that are being asserted once more ( 21) was looking at. But the rule to plead special 22 ) that have previously been denied and to wait for a ( 22) damages. I believe it's 1.210 or 1.200. It's in 23 ) special set hearing in order to do that. I suggest (23) our motion -- requires heightened pleadings. So 24 ) to Your Honor, is simply a transparent attempt at ( 24) by — just as an example to give Judge Crow, by his 25 ) further delaying getting this 2009 case set for (25) own admission Mr. Scarola has virtually changed 6 8 (1 ) trial. That's the reason why I have been insistent (1 ) nothing in his complaint. That assertion by its ( 2 ) upon dealing with this matter at an 8:45 hearing. (2 ) very nature clearly goes to the fact that the ( 3 ) because I firmly believe that when Your Honor takes (3 ) complaint has not properly been amended to add a ( 4 ) a look at this complaint you will find that that is (4 ) claim in punitive damages. ( 5 ) the only change and it does not warrant a special (5 1 And I apologize to the court, the special ( 6 ) set hearing after Your Honor has already granted (6 ) pleading requirement statute is 1.120(G) and 768.72 ( 7 ) leave to amend to assert a claim for punitive (7 ) of the Florida statutes, require different ( 8 ) damages. (8) pleading. ( 9 ) Just so that it is clear what has happened (9) THE COURT: So let me stop you and make sure I 10 ) here. I have highlighted on both the copy I (10) understand you. What you're saying is that even 11 ) provided to Your Honor and the copy for opposing (11) though I may have given permission based upon the 12 ) counsel each of the factual allegations that were (12) proffer made at the time of the hearing to plead 13 ) supported by record evidence that allowed Your (13) punitive damages you still have to plead sufficient 14 ) Honor to grant leave to assert the claim for (14) ultimate facts to establish punitive damage 15 ) punitive damages. No new factual allegations have (15) liability -- 16) been added to those that formed the basis to assert (16 ) MR. SCAROLA: Yes. Your Honor, and the case 17 ) the claim for punitive damages to begin with. So (17) law clearly supports that and based upon my 18 ) that's the reason why I have asked Your Honor to (18) communications with Mr. Scarola I realized that 19 ) deal with this at an 8:45. so that we can finally (19) this was going to be a problem that could not be 20 ) get a trial date in this 2009 case. (20) addressed in five minutes. We were going to need 21 ) Thank you, sir. (21) to convince you otherwise, which is again why I'm 22 ) THE COURT: Yes. ma'am. (22) requesting that you allow us more time to argue 23 ) MS. COLEMAN: Your Honor, before I respond to (23) this, because it's a very important issue. 24 ) that, respectfully I'm asking am I going to be (24) obviously. 25) compelled to argue my motion in this five minute (25) THE COURT: How much time do you need to 2 (Pages 5 to 8) WWW.USLEGALSUPPORT.COM EFTA00619849 9 11 (1 ) (2) (3) (4) (5) (6) (7) (8) (9) (10) (11) (12) (13) (14) (15) (16) (17) (18) (19) (20) (21) (22) (23) (24) (25) argue? MS. COLEMAN: I need at least 20 minutes to argue my point, Judge. THE COURT: I don't give 40 minute hearings. I only have 30 minute hearings. MS. COLEMAN: 15, I can do it in 15. THE COURT: Go ahead. MS. COLEMAN: You want me to argue it right (8) now? (9) THE COURT: I have 15 minutes. ( 10) MS. COLEMAN: I don't have all the case law ( 11 ) with me right now. We were set on a five minute ( 12) hearing. I was coming in here to request that you ( 13) give us a specially set hearing. Judge. If you're ( 14) going to compel me to go forward at this exact ( 15) moment — ( 16) THE COURT: Is the hearing about the stuff ( 17) I've got in front of me? You know, I'm pretty ( 18) familiar with the case law in which you've cited ( 19) here. These are all standard cases. These are not ( 20 ) unique. And so what I really want to know is what ( 21) the factual predicate is for your motion. The case ( 22) law is very clear. I understand the case law. I (23) don't think you got any new case law in here, do ( 24) you? (25) (1) (2) (3) (4) (5) (6) (7) (1) (2) ( 3 ) (4) ( 5 ) (6) ( 7 ) ( 8 ) ( 9 ) 10) 11) 12) 13) 14) (15) (16) 17) 18) 19) 20) 21) 22) 23) 24) 25) THE COURT: Is it something in addition to what's in your memorandum that you want to tell me? MS. COLEMAN: With the case law? No. Judge. I would like to be forwarded the opportunity to properly prepare and argue my point. I've been in your courtroom many. many times as you know -- THE COURT: I'm just asking a simple question. Is there something more than what you've outlined very articulately in the memorandum of motion that you need to argue or can I read it and understand it? MS. COLEMAN: I'm confident you can read it and understand it. Judge. but respectfully, the last couple of times we've been in here and we have not been permitted to outlay our argument. for example. the Motion for Protective Order, which we tried to get specially set for 15 minutes and Mr. Scarola would not agree. we get ruled against. I'm trying to do my job here. I'm trying to adequately present my client's position. I feel we have a very strong Motion to Dismiss. I'm asking this court to allow us the 15 minutes within which to argue it and to not permit — I don't know -- I don't have an -- THE COURT: When will you be ready to argue? 10 MS. COLEMAN: Any new case law from what. Judge? I don't know what's been submitted to you in the past. THE COURT: In support of your motion. MS. COLEMAN: In support of my motion, no. I filed it on the 18th. THE COURT: No. I mean, any recent cases that have changed the law in any manner. There is nothing new in the case law. What you're really doing is the case law as it applies to the allegations of this complaint presumably is what you're saying. MS. COLEMAN: Yes, I am. Judge. THE COURT: Okay. So tell me what's wrong with this complaint. MS. COLEMAN: I'm just -- Are you making us do this argument now? THE COURT: I'm not making you do anything now. I'm sitting here. I got the thing in front me. I said maybe we can argue it now. You're telling me you're not prepared to argue the motion? Is that what you're saying? MS. COLEMAN: I was prepared for a five minute hearing and I'm telling you. yes. I would prefer to- 12 (1) MS. COLEMAN: You can -- we have a UMC set for (2) Wednesday morning. If you'd rather set this for (3) Wednesday I'd be fine with that. (4) THE COURT: I have got time today, how about (5) that? I can get my calendar. Will you be prepared (6) to argue it today? (7) MS. COLEMAN: Judge. my office is in Broward (8) and I have depositions set today. I don't know (9) that I'll be able to do it today, but I'd be happy 10) to do it Wednesday. 11) THE COURT: Let's get you scheduled here. 12) Okay. 13) MS. COLEMAN: Thank you very much. 14) THE COURT: Do you have the ability to look 15) and see what your schedule is like right now? 16) MR. SCAROLA: I have my phone here. 17) THE COURT: Are you prepared to do that? 18) MS. COLEMAN: Yes, sir. I have my calendar 19) hew on my phone. 20) THE COURT: Go ahead and get your calendars. 21) Let's get your schedules here. You need 30 22) minutes. I'm going to go ahead and get it set. 23) This is one of the older cases on my -- I know 24) it had some procedural hiccups. but I want to try 25) and get it to the point where we can -- 3 (Pages 9 to 12) WWW.USLEGALSUPPORT.COM EFTA00619850 13 15 (1) (2) (3) (4) (5 ) (6) (7 ) (8) (9) 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) 25) Can you do it at 8:00 in the morning? You generally don't have things scheduled at 8:00 in the morning. MS. COLEMAN: Yes, sir, we have done that before. MR. SCAROLA: The only day that 8:00 would be a problem would be Wednesday. because I'm scheduled to be on a plane to Tampa Wednesday morning at 7:00. THE COURT: How about Monday the 11th, 8:00? MS. COLEMAN: I can do that. THE COURT: All right. Somebody notice it. Okay. MS. COLEMAN: Judge. if you do have the time now — l'HE COURT: We can do it at 8:15. too. MS. COLEMAN: That's fine. That's fine with me. Judge. THE COURT: 8:15. That will be better. 8:15 on Monday February the Ilth. MS. COLEMAN: Thank you. Judge. If you would like to address one small issue now that Mr. Scarola and I both agreed if we had time we would prefer that you address. You denied our Motion for Protective Order ( 1 ) documentation. ( 2) THE COURT: Okay. ( 3 ) MR. SCAROLA: Your Honor, this is the (4) pecuniary circumstances of discovery relating to ( 5 ) punitive damages. ( 6) THE COURT: Right. ( 7) MR. SCAROLA: It is already past due. It's (81 more than 30 days. I had suggested at the time of ( 9 1 the hearing that Your Honor should include a time 10 ) for response, because I anticipated this problem 1 1) and I requested ten days. There was no time for 12 ) response included in the order and opposing counsel 131 has said I want 30 days from the entry of the order 1 4 denying my motion for protective order, which would 1 5 1 give them a total of in excess of 70 days to 16 ) respond to this discovery. I believe that that's 17 ) entirely inappropriate. The filing of a Motion for 18 ) Protective Order does not relieve them of the 19 ) obligation to prepare and be ready to submit the 20 ) discovery in a timely fashion if the motion is 21 ) denied. So my request is that ten days from today, 22 ) which is now one week beyond where it was before, 2 31 that discovery response be submitted. That's the 24 ) request I made. 2 51 There is an ancillary issue. And if I may 14 1 last Thursday. ( 2 ) THE COURT: Is there a motion or something? ( 3 ) MS. COLEMAN: It's set on your docket for ( 4 ) Wednesday, but I believe Mr. Scarola said he was ( 5 ) going to bring everything if time permitted. ( 6 ) MR_ SCAROLA: I don't have that other file. ( 7 ) THE COURT: Basically, Judge -- (8) MR_ SCAROLA: I do have -- (9) MS. COLEMAN: I don't know that we even need a 1 0) tile for it. 1 1 You denied our Motion for Protective Order 12 ) last Thursday. You delineated the confidentiality 13 ) order that you would like entered in this case and 14 ) Mr. Scarola and I are working on different drafts 11 5) of that. However, you did not provide in your 11 6) order a date upon which our responses. whatever 17 ) they may be. to Mr. Scarola's discovery would be 18 ) due. So we had agreed 30 days from the date of 19 ) your order we offered to Mr. Scarola thinking that 20 ) was reasonable, but Mr. Scarola disagreed. So we 21 ) would ask you to please give us a date upon which 22 ) ow responses to his discovery -- 23 ) THE COURT: I don't remember what the 24 ) financial requests were right now. 2 5 1 MS. COLEMAN: Voluminous, over five years of 16 (1) approach, Your Honor? (2) THE COURT: Sure. (3) MR. SCAROLA: This is a copy of the order that (4) Your Honor entered. (5) THE COURT: Okay. (6) MR. SCAROLA: And Your Honor outlined what you (7) believed the appropriate terms of a confidentiality (8) order to be. I drafted a proposed confidentiality (9) order that exactly tracks the language in Your 10) Honor's order and I submitted it to opposing 11) counsel and they have not agreed to that 12) confidentiality order. which is no surprise. 13) because its one more way in which they will 14) attempt to delay the response to the discovery that 15) we are seeking. I would ask Your Honor to 16) simply -- 17) I don't believe that after Your Honor's 18) already entered the order that outlines all the 19) confidentiality provisions that another order is 20) necessary. but you contemplated another order. so I 21) would ask Your Honor to enter the confidentiality 22) order that you said would be appropriate. 23) MS. COLEMAN: Your Honor. I have not even read 24) that. It was e-mailed on Friday and I e-mailed 25) Mr. Scarola back right away -- and I can prove this 4 (Pages 13 to 16) WWW.USLEGALSUPPORT.COM EFTA00619851 17 19 (1 ) (2) (3) (4) ( 5) (6) ( 7) ( 8) ( 9) 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) 25) if I have to. I haven't had an opportunity to review it yet, much less send it to my client or my co-counsels -- THE COURT: Well, what it is is a bullet point of exactly what I said. MS. COLEMAN: I understand what it is, Your Honor, but -- THE COURT: Well, is there something you want more than in my order? MS. COLEMAN: I haven't read it. Yes, Judge, there — no, I would like to have it say what you say in your order, but there may be -- This is our protective order, Your Honor. This is to protect Mr. Epstein, my client. While I appreciate Mr. Scarola's constant opinions of the law and what should be submitted, its my client. I should at least at a minimum have a right to review it and edit it if I believe it's necessary. I'm not adding -- I don't anticipate adding anything that the court hasn't delineated in its order, but I think it's incumbent upon me as counsel of record for Mr. Epstein to at a minimum be able to review a confidentiality order that's going to order by Mr. Scarola's own constant words, a billionaire, to disclose all of his financial (1) MR. SCAROLA: Thanks. (2 ) MS. COLEMAN: An order regarding the discovery (3) due date or -- (4 ) THE COURT: Yeah. And whether or not I'm (5 ) going to require a confidentiality order and. I (6 ) mean -- basically -- I mean. I'm looking at my (7) order and what I -- I couldn't tell you what I was (8 ) thinking, but I spelled out everything that I (9 ) thought was necessary and only if you thought 10 ) something more then I was going to allow you to do 11 ) something different, but -- or less. 12 ) MS. COLEMAN: Respectfully. Judge. in my 13) granted less limited experience than Mr. Scarola in 14 ) the legal arena, if an issue arises with this 15) confidentiality order we were trying to place the 16 ) burden not on you purportedly drafted the 17) confidentiality order by nature of your order. but 18 ) rather having an agreed to confidentiality order 19 ) between the parties that you would merely sign 20 ) rather than using your court order and asking you 21 ) to rule on exactly what you just said what you 22 ) meant at the time you drafted it 23) THE COURT: Okay. I'm not sure what I'm going 24 ) to do, but I'll get you an order out here today. 25) Okay. 18 (1) information absent, you know, something being in (21 place that we need to review. And especially given (31 the situation of what's going on in other (4) litigations between these parties. (5) THE COURT: Well. I guess what I'm asking (61 is -- I mean. I outlined everything that I thought (71 was necessary in my order. And what I'm asking -- (8) certainly you've read my order. (91 MS. COLEMAN: I've read your order. Judge. I 10 ) have nor read Mr. Scarola's proposed 11) confidentiality order. 12) THE COURT: I'm not asking about the 13) confidentiality order. I'm going to ask you about 14) my order. What in addition to what I put in the 15) order would you want? 16 ) MS. COLEMAN: Judge. I read your order 17) Thursday afternoon. I don't remember. I wasn't 18) prepared to discuss the confidentiality order this 19) morning. I wasn't told it was going to be heard. 20) I wasn't told that Mr. Scarola was going to present 21) you with a copy of what he had drafted. 22) THE COURT: Okay. I'll get you an order out. 23) Okay. 24) MR. SCAROLA: Thank you very much. Your Honor.( 25) THE COURT: Have a great day. 11) (2) (31 (41 (51 (6) (71 (81 (91 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) 25) 20 MS. COLEMAN: Thank you. Judge. MR. SCAROLA: And I would respond to that if I had any idea at all what she just said. So I have no response. THE COURT: Excuse me? MR. SCAROLA: I said I would respond to that if I had any idea at all what it is she just said. but I don't. THE COURT: Thank you. MR. SCAROLA: Thank you. Your Honor. THE COURT: Have a great day. MR. SCAROLA: And you too, sir. (Proceedings concluded at 9:18 a.m.) 5 (Pages 17 to 20) WWW.USLEGALSUPPORT.COM EFTA00619852 21 (1) (2) (3) (4) (5) (6) (7) (8) (9) 10) 11) 12) 13) 14) 15) 16) 17) 18) 19) 20) 21) 22) 23) 24) 25) CERTIFICATE OF REPORTER I, Sara Storey, Florida Professional Reporter, State of Florida at Large, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript, page I through 20, is a true and complete record of my stenographic notes. Dated this 4th day of February 2013 in Palm Beach County, Florida. Sara Storey, Florida Professional Reporter S (Page 21) WWW.USLEGALSUPPORT.COM EFTA00619853 Page 1 A ability12:14 able12:9 17:23 absent18:1 absolutely 5:13 add8:3 added6:16 adding17:19,19 addition11:1 18:14 address 13:22,24 addressed8:20 adequately 11:20 admission :25 afternoon18:17 agree11:18 agreed13:23 14:18 16:11 19:18 ahead7:6,7 9:7 12:20,22 al2:7 allegations 5:12 6:12,15 10:11 allow8:22 11:22 19:10 allowed6:13 amend6:7 amended4:21,22,23 5:14 8:3 amendment 5:6 ancillary15:25 anticipate 17:19 anticipated 15:10 apologize8:5 appear4:25 APPEARANCES2:1 applies10:10 appreciate 17:15 approach4:17 16:1 appropriate 16:7 16:22 arena19:14 argue3:20 4:8 5:20 6:25 8:22 9:1,3,8 10:20,21 11:5,10,23,25 12:6 argument10:17 :15 arises19:14 articulately11:9 asked6:18 asking3:19 6:24 11:7,21 18:5,7 18:12 19:20 assert 5:4,10,11 5:17 6:7,14,16 asserted5:21 assertion5:8 8:1 attemptS:24 16:14 authorized21:6 available3:20 a.m1:16,16 20:13 B back16:25 based8:11,17 basically14:7 19:6 basis6:16 Beach1:2,17,18 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16:19,21 17:23 18:11,13,18 19:5 19:15,17,18 constant 17:15,24 contemplated 16:20 contravention 7:13 convince4:11 8:21 cooperating4:6 copy3:8 6:10,11 16:3 18:21 corporated4:8 counse14:13 6:12 15:12 16:11 17:22 count 5:1,2 counter-plaintiff 5:7 County 1: 2, 17, 18 21:12 couplo11:14 course 7:11 court1:1 3:6,11 3:15,21,24,25 4:12,19 5:10 6:22 7:2,6,8 8:5 8:9,25 9:4,7,10 9:17 10:4,7,14 10:18 11:1,7,22 11:25 12:4,11,14 12:17,20 13:10 13:12,16,19 14:2 14:7,23 15:2,6 16:2,5 17:4,8,20 18:5,12,22,25 19:4,20,23 20:5 20:9,11 Courthouse1:17 courtroom 1:17 11:6 co-counsels17:3 Crow1:14 7:17,24 D D3:1 damage 8:14 damages 5:5,9,11 5:18 6:8,15,17 7:19,22 8:4,13 15:5 date3:17,19 4:7 6:20 14:16,18,21 19:3 Dated21:11 dates3:23 4:13 DAVID1:14 day13:6 18:25 20:11 21:11 days14:18 15:8,11 15:13,15,21 dea16:19 dealing6:2 Defendantsl:9 2:7 delay16:14 delaying5:25 delineated 14:12 17:20 denied4:2,25 5:22 13:25 14:11 15:21 Denney2:7 denying15:14 depositions 12:8 different8:7 14:14 19:11 disagreed14:20 disclose17:25 discovery4:1 14:17,22 15:4,16 15:20,23 16:14 19:2 discuss18:18 Dismiss4:8 5:15 7:18 11:21 Dixie1:17 docket 14:3 WWW.USLEGALSUPPORT.COM EFTA00619854 Page 2 documentation 7:17 3:1 doIng10:10 drafted16:8 18:21 19:16,22 drafts14:14 drast 7:13 due14:18 15:7 19:3 E':1,1 edIt17:18 Edwards1:8 5:7 enter16:21 entered14:13 16:4 _6:18 entirely15:17 entry15:13 Epsteinl:4 3:17 17:14,22 especially18:2 ESQUIRE2:5,10 establish8:14 et2:7 evidence6:13 exact9:15 exactly16:9 17:5 19:21 example7:24 11:16 excess15:15 Excuse3:3 20:5 experience 19:13 e-mailed16:24,24 F fact 8:2 facts8:14 factua15:12 6:12 6:15 9:22 familiar9:19 fashion15:20 February1:15 13:20 21:11 feel 11:20 FIFTEENTH1:1 file 14:6,10 filed3:17 10:6 filing15:17 finally6:19 financia114:24 17:25 find6:4 fine7:12 12:3 13:17,17 firmly6:3 first3:4 five4:4,10 6:25 7:8 8:20 9:12 10:23 14:25 FL2:4, 8 Florida1:2,18,22 8:7 21:4,5,12,20 follows 7:9 foregoing21:7 formed6:16 Fort2:4 forward9:15 forwarded11:4 fourth4:21,22 FPR 1:21 Friday16:24 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