JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,\
and [REDACTED] J, [REDACTED],\
individually.
Defendants.
IN THE CIRCUIT COURT OF THE\
FIFTEENTH JUDICIAL CIRCUIT IN\
AND FOR PALM BEACH COUNTY,\
FLORIDA
CASE NO. 502009CA040800XXXXXXMBAG
JUDGE: [REDACTED]
FILED\
2013 FEB 26 PM 18\
SHARON R. BOCK.\
PALM BEACH COUNTY\
CIRCUIT CIVIL\
CIRCUIT COURT
**PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND\
AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF\
[REDACTED] FOURTH AMENDED COUNTERCLAIM**
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the *Florida Rules of Civil Procedure*, hereby files his Answer and Affirmative Defenses to Defendant/Counter-Plaintiff [REDACTED] [REDACTED] ("[REDACTED]") Fourth Amended Counterclaim ("Counterclaim"), and states:
1. 1. Epstein admits that the Counterclaim alleges an amount within the jurisdictional purview of the Court, but denies that [REDACTED] is entitled to said amount.
1. 2. Epstein is without knowledge as to [REDACTED] residential status, but admits that he is an attorney licensed to practice law in the State of Florida.
1. 3. Epstein admits that he is *sui juris*, but denies that he is a resident of Palm Beach County, Florida.
1. 4. Epstein admits that he entered into a plea agreement that resulted in a felony conviction. Epstein further admits that the terms and conditions of the agreement speak for themselves. To the extent that [REDACTED] has inaccurately summarized or interpreted any provision thereof in Paragraph 4 of his Counterclaim, Epstein denies the allegations.
1. Epstein admits that he was a party to civil actions brought forth by purported victims, but is without knowledge as to any further investigation by federal law enforcement, or relationship with any other purported victims and therefore denies these allegations and demands strict proof thereof.
1. Epstein admits that, during certain times throughout the litigation, he asserted his rights against self-incrimination as afforded to him by the Fifth Amendment to the United States Constitution. Epstein denies the remaining allegations contained in Paragraph 6 and demands strict proof thereof.
1. Epstein denies Paragraph 7, except for the allegation therein stating that is involved in pending litigation in Federal Court under the Federal Crime Victims' Right's Act.
It Nt 8. Epstein denies each and every allegation " us' " Vve • Paragraph 8 and demands strict proof thereof.
9. Epstein denies each and every all'en fontained in Paragraph 9 and demands strict proof thereof.
1. Epstein denies each and every allegation contained in Paragraph 10 and demands strict proof thereof.
1. Epstein its that some of the causes of action filed by him against are delineated h 11 and its subparts. To the extent that has inaccurately SUMIllal or interpreted any provision thereof in Paragraph 11 of his Counterclaim, Epstein denies the allegations.'
1. Epstein admits that in one of his Complaints he alleged some of the causes of action against as specifically stated in Paragraph 11 and its subparts, but denies that he has
fails to attach a copy of Epstein's Complaint or even reference the version of the Complaint to which he refers in this allegation.
proof thereof. 14. Epstein denies each and every allegation contained n'graph 14 and demands strict
ever asserted a cause of action for Civil Theft against as alleged in Paragraph 12. To the extent that has inaccurately summarized or interpreted any provision of Epstein's "Complaint" in Paragraph 12 of his Counterclaim,2 Epstein denies the allegations. Epstein further denies the remaining allegations contained in Paragraph 12 and demands strict proof thereof.
13. Epstein denies each and every allegation contained in Paragrapgh 13 and its subparts and demands strict proof thereof. With respect to subsection (d) of Paragraph 13, Epstein further denies that actions were afforded absolute protection under the litigation privilege. See Delmonico v Traynor, 38 FLW S 106 (February 14, 2013).
-C\\ 15. Epstein denies each and every allege< ' di\\ co 4 'fled in Paragraph 15 and demands strict proof thereof.
16. Epstein denies each and every allegation contained in Paragraph 16 and demands strict proof thereof.
01. Epstein denies each and every allegation and claim for damages that is contained in Paragraph 17, including its subparts, and demands strict proof thereof.
Epstein denies that is entitled to any demand made in his "WHEREFORE" clause, including any assertion of alleged Punitive Damages.
18. Epstein admits that the Counterclaim alleges an amount within the jurisdictional purview of the Court, but denies that is entitled to said amount.
2fails to attach a copy of Epstein's Complaint or even reference the version of the Complaint to which he refers in this allegation.
19. Epstein is without knowledge as to residential status, but admits that he is an attorney licensed to practice law in the State of Florida.
01. Epstein admits that he is sui juris, but denies that he is a resident of Palm Beach County, Florida.
01. Epstein admits that he entered into a plea agreement that resulted in a felony conviction. Epstein further admi themselves. To the extent that terms and conditions of the agreement speak for has inaccurately summarized or interpreted any provision thereof in Paragraph 21 of his Counterclaim, Epstein denies the allegations.
01. Epstein admits that he was a party to civil actions brought forth by purported victims, but is without knowledge as to any further investigation by federal law enforcement, or relationship with any other purported v. therefore denies these allegations and demands strict proof thereof.
01. Epstein admits that, during n s throughout the litigation, he asserted his rights against self-incrimination as afforded to him by the Fifth Amendment to the United States Constitution. Epstein denies the remaining allegations contained in Paragraph 23 and demands strict proof thereof.
01. Epstein denies each and every allegation contained in Paragraph 24 and demands strict proof thereof.
01. Epstein denies each and every allegation contained in Paragraph 25 and demands strict proof thereof.
01. Epstein denies each and every allegation contained in Paragraph 26 and demands strict proof thereof.
01. Epstein admits that some of the claims initially filed by him against are delineated in Paragraph 27 and its subparts. To the extent that has inaccurately summarized or interpreted any provision thereof in Paragraph 27 of his Counterclaim, Epstein denies the allegations.3
01. Epstein admits that in one of his Complaints he alleged some of the causes of action against as specifically stated in Paragraph 27 and its subparts, but denies that he has ever asserted a cause of action for Civil Theft against as alleged in Paragraph 28. To the extent that has inaccurately summarized or interpreted any provision of Epstein's "Complaint" in Paragraph 28 of his Counterclaim,4 Epstein denies the allegations. Epstein denies the remaining allegations contained therein and demands strict proof thereof.
01. Epstein denies each and every allegation contained in Paragraph 29, including its subparts, and demands strict proof thereof. With respect to subsection (d) of Paragraph 29, Epstein further denies that actions were afforded absolute protection under the litigation privilege. See Delmonico v Traynor, 38 FLW S 106 (February 14, 2013).
01. Epstein denies each and every allegation contained in Paragraph 30 and demands strict proof thereof.
01. Epstein denies each and every allegation contained in Paragraph 31 and demands strict proof thereof.
01. Epstein admits that he amended his Complaint over the course of the litigation, and that some counts contained in his Complaint were dismissed by the Court without prejudice. However, Epstein denies that this constitutes abandonment of his claims and/or a bona fide
fails to either attach the Complaint to his Counterclaim or reference the specific Complaint to which e ng in Paragraph 27.
fails to either attach the Complaint to his Counterclaim or reference the specific Complaint to which he is referring in Paragraph 28.
termination of his claims in favor. Epstein denies any and all remaining allegations contained in Paragraph 32 and demands strict proof thereof.
33. Epstein denies each and every allegation and claim for damages that is contained in Paragraph 33, including its subparts, and demands strict proof thereof.
Epstein denies that is entitled to any demand made in his "WHEREFORE" clause, including any assertion of alleged Punitive Damages. AN4
### AFFIRMATIVE DEFENSES
### FIRST AFFIRMATIVE DEFENSE ca. 0
For his First Affirmative Defense, Epstein states that Abuse of Process claim fails to state a claim upon which relief can be granted as is, required under Rule 1.110 of the Florida Rules of Civil Procedure. did not, nor will he ever be able to, assert the three requisites required to properly plead same; to wit: I) an illegal, improper, or perverted use of process after it issues ; 2) an ulterior motive or purpose in exercising the illegal, improper, or perverted process; and 3) damages resulting therefrom. S & I lnvs. v. Payless Flea Mkt, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 S d 1051, 1055 (Fla. 4th DCA 1987).
### V SECOND AFFIRMATIVE DEFENSE
econd Affirmative Defense, Epstein states that Malicious Prostettion claim fails to state a claim upon which relief can be granted as is required under Rule 1.110 of the Florida Rules of Civil Procedure. Specifically, the requisite of a "bone-fide termination of the original proceeding in favor of the present plaintiff' as delineated by the Florida Supreme Court as one of the legally-mandated elements to bring forth a Malicious Prosecution claim, has not, nor can it, be satisfied. See Alamo rent-A-Car v. Mancusi, 632 So.
AS,
2d 1352, 1355 (Fla. 1994). The "original proceeding" to which refers in his Counterclaim is, in fact, the case Epstein voluntarily dismissed without prejudice and could re-file at any time. A "bona-fide termination" would prohibit re-filing. As such, there has not been the required "ending in a manner indicating innocence of the charges or allegations contained in the first suit." See Doss v. Bank of America, N.A., 857 So. 2d 991, 994 (Fla. 5th DCA 2003). See also Yoder v. Adriatico, 459 So. 2d 449, 451 (Fla. 5th DCA 1984) (stating that the tort of malicious prosecution requires, as an element, the prior termination of that claim and therefore malicious prosecution may not be brought as a counterclaim).
Indeed, it is well-settled law that an action for Malicious Prosecution cannot be filed until the original action is concluded, and that counts of a Complaint that are dismissed without prejudice are not deemed a "bona fide termination" in that party's favor. "Where dismissal is on technical grounds, for procedural reasons, or any other reason not consistent with the guilt of the accused, it does not constitute a favorable determination." Union Oil of California v. John 468 So. 2d 349 (3d DCA 1985). Accordingly, fails to state a claim upon which relief may be granted.
### (S, THIRD AFFIRMATIVE DEFENSE
\*rd Affirmative Defense, Epstein states that Counterclaim fails to properly plead his damages as required under the Florida Rules of Civil Procedure. See Miami National Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) (stating that a litigant cannot recover as damages his own time for participating in a litigation when counsel is engaged to represent him). further pleads damages for injury to his reputation, mental anguish, anxiety, and embarassment, which are impermissible and improperly plead.
Finally, fails to properly plead punitive damages as required by the Florida Rules of Civil Procedure.
Most importantly, however, Epstein states that has not, nor will he, suffer any damages as a result of any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted from an unknown ■ **practitioner to a partner at Rothstein, Rosenfeldt, Adler. Moreover, still utilizes his litigious association with Mr. Epstein at his new firm =, Jaffe, Weissing, Fistos, & Lehrman, both on its firm website and firm Facebook page, to disparage Epstein, to seek new clients on whose behalf he can sue Epstein, to attract additional plaintiffs for whom he can file suit, and to achieve notoriety with the press. See Composite Exhibit A attached hereto.**
### **FOURTH AFFIRMATIVE DEFENSE**
**For his Fourth Affirmative Defense, Epstein asserts that he is afforded absolute immunity pursuant to the "Litigation Privilege" because his actions were connected with, relevant to, and material to, the cause at hand. The Litigation Privilege protects actions taken that are related to the judicial proceeding. Litigation privilege "arises immediately upon the doing of any act required or permitted by law in the due course of the judicial proceedings or as necessarily preliminary thereto." Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992). This absolute immunity afforded to Epstein pursuant to the Litigation Privilege appears on the face of the Counterclaim as filed by M. As such, is barred from proceeding with this litigation.**
**Epstein specifically reserves the right herein to amend these defenses and plead other affirmative defenses that may become known during his continuing investigation of this action and during discovery in this case.**
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 February 21, 2013.
Tonja Haddad Coleman, Esq.\
Florida Bar No.: 176737\
Tonja Haddad, PA\
5315 SE 7th Street\
Suite 301\
Fort Lauderdale, Florida 33301\
954.467.1223\
954.337.3716 (facsimile)\
Attorneys for Plaintiff
#### SERVICE LIST
CASE NO. 502009CA040800XXXXMBAG
Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409
Jack Goldberger, Esq. Suite 1400 West Palm Beach, FL 33401 CO 'S Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South
Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301
', J. IM Jaffe WeissinEgs Fistos Lehrman 425 N Andrews Avenue Sui Fort Lauderdale, Florida 33301 * te 2
Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33 Dee®FredHadrkaw.
1.1
Jaffe, Weissing, Fistos Et Lehrman, P.L.
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## September 2012
Attorney Brad ( A. ° who is representing several young men who say former youth pastor sexually abused and physically abused them was interviewed by CBS4 MIAMI.
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### Firm Supports RAINN DAY - September 27th
Jaffe Weissing is proud to support Rape, Abuse & Incest National Network's RAINN Day September 27th. RAINN Day is RAINN's annual campaign to raise awareness and educate students against sexual violence on college campuses. RAINN DAY is agrassroots program designed to empower college students to raise awareness of sexual violence and recovery resources on their campus. Click here to learn how Jaffe Weissing helps crime victims and victims of sexual assault.
Naples News interviews attorney Steven Jaffe regarding his case involving elder abuse. A care facility took control of an ailing dementia patient's trust account 30 days before her death, with the assistance of a Fort Myers attorney. The case which was filed in 2011 is still pending.
Zambrano Named to Million Dollar and Multi-Million Dollar Advocates Forum®
Attorney Gabriel F. Zambrano has been certified as a member of both the Million Dollar Advocates Forum® and the Multi-Million Dollar Advocates Forum®.
Fewer than 1% of U.S. lawyers are members. Forum membership acknowledges excellence in advocacy, and provides members with a national network of experienced colleagues for professional referral and information exchange in major cases. Members of the Multi-Million Dollar Advocates Forum must be Life Members of the Million Dollar Advocates Forum and must have acted as principal counsel in at least one case which has resulted in a multi-million dollar verdict, award or settlement.
October 2012
Gary FJA President Presents Civil Justice & Merit Retention to FAMU Law Students
FJA President Gary meets with Florida Agricultural and Mechanical University (FAMU) law students to discuss the civil justice system and view the documentary "Hot Coffee. Here Gary shows his appreciation to the FAMU Law School Ambassadors for the Florida Justice Association (FJA).
#### FJA President Gary Retention & Judicial Addresses Law Students on Merit ys em
Florida Justice Association President Ga spoke to more than 120 law students at the Coastal Law School Outreach Reception about the importance of Justice and Merit Retention and why it matters. Students also watched ashowing of "Hot Coffee," the 2011 documentary film that analyzes and discusses the impact of tort reform on the United States judicial system. Four other colleges and universities will be participating in similar discussions over the next couple of weeks.
### Firm Attorneys Attend & Present4110.NP7 Seminar
Several of the firm's attorneys are attending the Mass Torts Made Perfect Seminar this week (October 10-13). Attorneys Ga and Matt Weissing presented Qui Tam — Blowing the Whistke on Corporate raud at the Securities and Business Torts Breakout session of the Mast' Torts Made Perfect Seminar on October 12th.
### Class Action Final Aeproval Granted
We obtained final approval of a Class Action case against Continental Casualty Company (-CNA") for systematic denial of long-term care insurance claims. We're very pleased to recover meaningful insurance benefits for a deserving group of Floridians and we are equally pleased to protect the status of nurse registries as covered providers
**Gabe Zambrano, Gary [REDACTED]** (FJA President) and **Seth Lehrman** attended the Florida Justice Association's (FJA) Founder's Awards Dinner in Boca Raton on October 5th.
**Gary [REDACTED], Sr. Addresses Florida Supreme Court Justices**
Attorney **Gary [REDACTED] Sr.**, argued before Florida's Supreme Court yesterday on behalf of the Respondent regarding an uninsured motorist insurance policy claim.
## Supports National Crime Prevention Month
**[REDACTED]** Jaffe Weissing proudly supports National Crime Prevention Month – October 2012, sponsored by the **National Crime Prevention Council** (NCPC). National Crime Prevention Month recognizes and celebrates the practice of crime prevention, while promoting awareness of important issues such as victimization, volunteerism, and creating safer, more caring communities. This year the firm wants to raise help awareness of the following crimes: **sexual abuse & assault; negligent security and inadequate security;** and nursing home abuse and neglect safety issues. Visit our **Facebook, Google+ and Twitter** feeds for ways to protect you and your family.
# weico lit affe Weissing tr ess Releases t our welnite.
Here you will find our breaking news and announcements from our firm. We welcome any inquiries. If you have any questions regarding a release or case, \_please contact us. For Archived Press Release click here.
## August 2012
### Jury AwardsJ13 Million to Woman Injured in Plummeting levator Accident
Partner Brad received a \$13 million verdict on August Brad Edwards31. following a twoweek jury trial. Thirteen years ago. Janice Beasley (41 years old) was riding in an elevator that plunged several floors before crashing to an abrupt stop. have confined her 30,1V to a wheelchair for nearly 13 years. Ms. Beasley sustained significant permanent injuries whie defendants sought to avoid responsibility for this acCiderit, which Ms. Beasley believed was both preventable and the cause of more than a decade of life-changing medical problems.
### Five Jaffe WeissThg attorneys Included in The wyers in America®
701 The firm is pleased to announce that five of the firm's attorneys have been selected by their peers iisilusion in The Best Lawyers in America® 2013 (Copyright 2012 by Woodwara, Inc. of Aiken, SC). The following attorneys were selected in their respective pratie areas:
Gary M. Farmer, Jr. - Mass Torts Litigation / Class Action - Plaintiffs Steven Jaffe - Mass Torts Litigation / Class Action - Plaintiffs Matt WsisSinG - Personal Injury Litigation - Plaintiffs - Personal Injury Litigation - Plaintiffs Sr. - Appellate Practice
## Firm Sponsors ABOTA Annual Professionalism Seminar
The American Board of Trial Advocates (ABOTAI, Fort Lauderdalegir held it's 1st Annual Professionalism Program in honor of Henry T. Latimer. Jaffe Weissing was one of several sponsors, where members of the Judiciary, their Judicial Assistants, and local members of the Bar explored issues facing the profession from the prospective of these groups. For photos of the event visit ABOTA's Facebook Page.
### Justice for Amputee in Plane Propeller Accident
The attorne s and staff at Jaffe Weissin • are proud to haVe been able to assist out client Mr. , whose arm had to be amputated as a result of an airplane propeller accident, in his pursuit of iustice and fair compensation, and to hold Greenwich Insurance Co. to its obligations. This case highlights the importance of obtaining insurance coverage to account for the possibilitfliat'en injury could occur on ones premise and how too often insurance companies disregard their contractual obligations and leave prudent businesses exposed to potentially devastating judgments.
### Floridians at the Mercy ofAr. t si. ve Insurance Companies "
Read Gary M. Jr's. important editorial on State Farm's recent request for a 14.9% insurance rate increase. Why does State Farm Insurance Co. seek a "statewide average increase"? The simpe and sad answer: Because it can.
So what should homeo Pi and renter do? Ask for additional public hearing regarding the renters' insurance and all other insurance rate increases. And tell the Office of Insurance Regulation to reject State Farm's unreasonable price hikes.
Click Wicto read complete editoral. For the Tallahassee Democrat, click here.
## JULY 2012 A Torch That For Justice
Meet the ciillorida Justice Association President Gary M. Jr. In the case of the family, the torch has been passed. Click he entire article.
## Firm Cases Recognized as Top Florida Verdicts & Settlements for 2011
Firm Attorney's Matt Weissing, Brad and Gabriel F. Zambrano's cases were recently published in the Daily Business Review and VerdictSearch.com's Top Florida Verdicts an Settlements for 2011.
Matt Weissing and Brad Edward's premises liability case was against Festival Fun SIC Doing Business as Boomers. A young man with a promising football career was shot in the parking lot and sustained permanent nerve injury due to the property's lack of security. Following a two-week trial, a Broward County jury re .a verdict in favor of the plaintiff for \$4.255,280.00.
Gabriel F Zambrano and co-counsel's product liability case was against R.J. Tobacco Company and Phillip Morris. They represented a widow whose husband was a smoker. The case alleged that the cigarettes caused the man's fatal lunch cancer. A jury returned a verdict in favor of the plaintiff for \$3.551.277.00.
### Class Action CaseCk? nst CNA Receives Preliminary Appro
Our client's class action iaagainst CNA, for Attorney's Steven Jaffe and Mark Fistosdiscrimination against Nurse Registries in FL, has received preliminanktikproval from Federal Judge Zlock.
lee Weissing attorneys Steven Jaffe and Mark Fistos were named Class Counsel. Final approval hearing is set for September 27th, 2012.
"We have total confidence that Judge Zlock will enter a final order at the September hearing. thus ending the discriminatory practices of CNA," said Jaffe. "Nurse Registries around the state should be very happy."
## Gabriel F. Zambrano Joins Jaffe Weissing
We are leased to announce that trial attorney Gabriel F. Zambrano has joined the Jaffe Weissing team. Zambrano's practice will focus on mass torts defective drugs, defective medical products, personal injury and wrongful death litigation.
Zambrano gained national prominence as an early advocate on behalf of girls and women that suffered life altering blood clots, strokes or heart damage from use of the DROSPIRENONE (DRSP) containing birth control pills trademarked and manufactured by BAYER HEALTHCARE PHARMACEUTICALS: YASMIN. YAZ, BEYAZ & SAFYRAL.He is currently accepting and investigating cases involving PRADAXA (DABIGATRAN ETEXILATE), a FDA blood thinner and NUVARING VAGINAL RING contraceptives linked to fatal blood clots, tit, pulmonary emboli and deep vein thrombosis.
Zambrano is also fluent in Spanish.
### JUNE 2012
# The Florida Justice Association Re sAchievements of Attorney Gay M. Jr.
The Florida Justice Association (FJA) recognized attorney Gary M. Jr., as a recipient of their EAGLE Legend Award on Friday, June 15th at the Annual Convention on Marco Island. The EAGLE Legend Award is one of FJA's highest honors for lifetime leadership and commitment to supporting the goals of the FJA in protecting the legal rights and safety of the injured and Florida's Families. has personally given more than \$100,000 to FJA throughout his legal career.
In addition, the FJA presented with the EAGLE Top Recruiting Champion Award in recognition for recruitin and raising the most EAGLE money during 2011-2012. The FJA also presented with the 2012Gold EAGLE Award for gaining distinction at the highest level of commitment to the values of FJA founders (time, financial resources and energy) by exhibiting a steadfast duty to protect and defend civil justice.
### Attorney Gary M.FillInstalled As President of the ustice Association
Attorney, Gary M. Jr. was installed as President of the Florida Justice Association (FJAI astatewide legal or anization comprised of civil trial lawyers in the State of Florida. was
Annual officially sworn in as the 53rd President during the Florida Justice Association's Club & Convention held on Friday, June 15, 2012, at the Marriott Beach Resort Golf Spa on Marco Island.
### Action Judge Grants Final Approval in David J. Stern Class
U.S. District Judge Robert N. Scola. Jr., entered an order on June 8, 2012, granting final approval of the class action law suit involving foreclosure attorney David J. Stern for violations of federal labor laws by him former employees. Attorneys Steven Jaffe. Gary las. Mark Fistos, and Seth Lehrman, along with co-counsel Dawn Rapoport and Chandra Doucette represented a class of hundreds of former employees of the Law Offices of David Stern, P.A., DJSP Enterprises, Inc. and Stern's affiliated foreclosure processing businesses.
## Read Gary 2011 Legislation Session Review in
Attorney Gary takes a look back at the 2012 Legislative Session in the South Florida Legal Guide. is an active Florida Justice Association lobbyist. who has spent more than six weeks each year for the past seven, working only on consumer protections and access to the courts.
## FMSpeaks to Studentiratthcal
Attorney Gary M. Jr. spoke to students at Heron Heights Gary FarmerElementary School in Parkland, Florida on June 1st on the importance of the Bill of Rights) V
### MAY 2012
included in The National Trial Lawyers Association's Top 40 Under 40
Attorney Brad has been included as a member of The National Trial Lawyers Association's Top 40 Under 40. This invitation is extended exclusively to those individuals who exemplify superior qualifications, trial results, and leadership as a young lawyer under the age of 40.
#### Jaffe Presents at Private Care Association's Best Practices Conference
Attorney Steve Jaffe presented "Current Litigation Trends When Dealing With Denials on Long Term Insurance" at the 2012 Private Care Association of Florida's Best Practices Conferences for Registries in Fort Lauderdale.
### Crohn's & Colitis Fundraiser - 4th Largest Ever
Attorney Steve Jaffe thanks everyone who donated and Team Lyndsay - Take Steps & Be Heard - Crohn's & Colitiswalked for Team Lindsay in the 2012 Take Steps for Crohns & Colitis on Saturday, April 28, 2012, at Arts Park on Young Circle in Hollywood. Team Lindsay helped raise more than \$5500, which helps support patient programs, education. and furthers crucial research. The entire even raise over \$160,000 - the 4th largest fundraiser.
### Brad Runs for Victim's Rights
Run To Remember 5KAttorney Brad participated in the. C . Broward Victim's Rights Coalition's nnua un to Remember 5k in Hollywood on April 28, 2012. The event raised awareness and lute benefit crime victims in Broward County.
#### Brad Presents Seminar on Enforcing Nitg,thts A
Attorney Brad an OVC Training Consultant, presented an 8-hour seminar on "Enforcing Victims' Rights" as part of the Palm Beach Victims' Rights Coalition's Extending the Vision Reaching Every Victim Program on April 26, 2012, in West Palm Beach. The seminar. which was part of a week-long series of programs by the Palm Beach Victims' Right Coalition, was also part of National Crime Victims' Rights Week (April 22-28).
#### Presents webinar on Maximizing Recovery for Sexual Abuse Brad Victims
Attorney Brad presented an important online webinar on April 25, 2012, on "Maximizing Recv for Sexual Abuse Victims" as part of SeminarWeb Live! FJA Webinar. This presentation was part of National Crime Victim's Rights Week.
### Gary Parini, Presents at Auto Insurance Seminar
Attorney Gary M. Jr. presented "Constitutional Issues Arising Under 'New PIP— at the Florida Justice Association's Auto Insurance Seminar in Orlando on April 26
### Gary Presents at National Trial Lawyers Association Conference
Attorney Gary M. Jr. presented "State Attorney General Gary FarmerActions in Drug Cases: Are You Wasting All of Your Hard Work?" at the National Trial
**Lawyers Association's Mass Tort Made Perfect Conference in Las Vegas on April 20, 2012.**
**Gary IIIII, Sr. Presents at National Trial Lawyers Association Conf**
**Ga Sr. was part of a panel that discussed 'The Gary M. , ects of the Precedent-Setting Mensing & Kendall ns" at the National Trial Lawyers Association's Mass Tort Made Perfect Conference in Las Vegas on April 18, 2012.**
**Jaffe Weissing Support National Crime Victims' Rights ee**
**i i.ne Victims' Rights Week - April 22 - 28, 2012, sponsored by the U.S. Department of Justice Office for Victims of Crime (OVC). To learn about how we help crime victims visit: \_% www.pathtojustice.com, www.iusticetovictims.com, or www.abuseandassault.com. . Jaffe. Weissing, , Fistos & Lehrman proudly support National**
**Jaffe Weissing Advocates National k. Assault Awareness Month**
Jaffe, Weissing, , Fistos & Lehrinan,Sexual Assault Awareness Month (SAAMj - April 2012, sponsored by the the National Sexual Violence Resource Center (NSVRC1. View Release
## MARCH 2012 Cl e
Brad Presents at Florida Justice Association's Workhorse Seminar
Attorney Brad presented "Maximizing Recovery for Brad EdwardsSexual Abuse Victims" as part of the Florida Justice Association's Workhorse Seminar on March 23 in Orlando.
N - Brad devotes a large amount of his practice to sexual abuse and sexual assault cases. He is a major advocate for victim's rights and has provided hundreds of hours of probono services each year to Victims Advocates Services and victims' rights groups throughout Florida.
Gary Presents at Florida Justice Association's Workhorse Seminar
• Attorney Gar M. Jr. presented Gary Farmer"Everything You Always Want Ow About Qui Tam Cases - But Were Afraid to Ask" at the Florida Justice Association's Workhorse Seminar on March 22 in Orlando.
Gary M. Sr.'s 4111Ruling Quoted in The Atlantic Magazine Regardi rayvon Shooting
Ga Sr.'s 4th DCA opinion was quoted in The Atlantic regarding the Trayv shooting... Here's how one Florida appellate judge, in a 2006 ruling. interpreted the low legal threshold necessary to move the burden of proof on self-defense from people like Zimmerman to prosecutors
To repeat. the law did not require defendant to prove his justification of self-defense to any standard ...measuring an assurance of truth. He did not have to prove the exigency of self-defense to a near certainty (reasonable doubt) or even to a mere probability (greater weight). His only burden was to offer additional facts from which it could be true, that his resort to such fo have been reasonable (emphasis in original). Click this link to read Mr. 2006 ruling.
### Support Team Lindsay - Crohn's & ColitcTake Steps Walk
Once again Steffi and I (Steve Jaffe) have formed Team Lyndsay - Take Steps & Be Heard - Crohn's & ColitisTeam Lindsay to walk in our annual Take Steps Walk on Saturday April 28, 2012. This year the Walk will be held in A NEW LOCATION at ArtsPark on Young Circle in Hollywood. Last year's event drew more than 1,500 people and raised over 5200,000. This year's event promises to be a fun filled evening for the entire family.
As you all know our daughter Lindsay was diagnosed with Crohn's disease when she was 15 years old. She has done remarkably well for herself despite the flair ups and hospitalizations that she has endured over the years. She became an accomplished scholarship athlete, playing soccer at Appalachian State University. She has graduated and is pursuing a career in Sports Administration. We are so proud of her. Unfortunately, others have not fared as well as Lindsay, nearly 1.5 million Americans, many who are children suffer from Crohn's and Colitis and the number of people being diagnosed each year is increasing. The funds we raise through the Take Steps Walk will help support world class scientific research and sponsor educational programs and services for those afflicted with these diseases. Our hope is that others will be able to manage the disease as well as Lindsay has so far.
**We would really appreciate your support. Please visit Team Lindsay page. Just click on this link and sign up to be a team member on Team Lindsay. It will be a fun night. There will be plenty of food and entertainment, if you are unable to attend the walk, any donation is greatly appreciated.**
#### **Firm Hosts Press Conference for Attorney Representing Trayvon Family**
**Crump & Gary Farmer r hosted a con erence today for Attorney Crump of Crump in Tallahassee, who is representing Trayvon famil the young teenager shot and killed by watch captain Zimmerman. Here Attorney Crump talks to Attorney Gary M. Jr. before the news conference. For more photos of the news conference click here.**
### **Former Employees of David Stern Agree to Settlement**
**Approximately 800 former employees of foreclosure attorney David J. Stern, who alleged that Stern and DJSP Enterprise did not give them 60 days notice as required by the Federal Worker Adjustment and Retraining Notification or WARN Act, have reached . . inary settlement. Our firm andkoaimsel Dawn Rapoport and Chandra Doucette represent the named plaintiffs and class members. A final hearing before U.S. District Judge Ursula Ungaro will be held in Miami in June. Media coverage includes the Sun-Sentinel the pally Business Review.**
### **Seth Lehrman Guest Lectures\*?o Southeastern University Law School**
**Attorney Seth Lehrman wet a guest lecturer at Nova Southeastern x University's Law School. Seth presented on professional responsibility and ethics. His lecture focused on protecting clients' rights following the dissolution of a law firm.**
**Seth Lehrm**
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## Sexual Abuse I Sexual Assault
Sexual A use victims are not alone and they have rights, if and when they are ready to pursue them. At Jaffe Weissing, we want to empower victims to come forward, report crimes and hold perpetrators accountable; thereby educating the community and inspixitig others to do the same.
## Sexual Abuse Cases Under Inces gation
### Looking for Witnesses in Alleged Sexual Abuse Cases
We support crime victim's cases with intensive factual and legal research. We are investigating the following matters and issues that clients and other have brought to our attention. We are currently searching for witnesses to assist us in the following cases. If you have information, please contact its hat: or call 888-670-2451. You can remain anonymous.
- YOUTH PASTOR J. LONDON- Our law firm is actively investigating and representing victims claiming sexual abuse by former Youth Pastor.). London. Click video below to see exclusive interview.
- JEFFREY EPSTEIN (hettistered Sex Offender) Our law firm prosecuted numerous civil cases against registered sex offender Jeffrey Epstein. He is known to have molested children in various places, including on his private airplane. He is a registered sex offender in Florida, New York and the Virgin Islands.
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If you have any information about his molestation of children or other crimes of his that are known to you, please call our law firm.If you were a former employee or a victim yourself, or have any information regarding his criminal activity, please contact us. Your name can remain anonymous.
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