EFTA01108130.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, -vs- SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. HEARING BEFORE THE HONORABLE JUDGE DAVID CROW Monday, February 4, 2013 9:01 a.m. - 9:18 a.m. Palm Beach County Courthouse, Courtroom 9C 205 North Dixie Highway Palm Beach County, Florida Stenographically Reported By: Sara Storey, FPR Florida Professional Reporter WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108130  1 APPEARANCES: 2 On behalf of the Plaintiff: 3 Tonja Haddad, P.A. 315 SE 7th Street 4 01 5 BY: TONJA HADDAD, ESQUIRE 6 7 On behalf of the Defendants: Searcy, Denney, Scarola, et al. s 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 9 10 BY: JACK SCAROLA, ESQUIRE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108131  1 PROCEEDINGS 2 3 MS. COLEMAN: Excuse me one moment. I'm 4 sorry. The first page of that notebook I need to 5 take out. Can I just grab my -- they're my notes. 6 THE COURT: I can't read your notes? 7 MS. COLEMAN: Well, I wouldn't want to give 8 you my notes without giving a copy to Mr. Scarola, 9 because that would be inappropriate. 10 Good morning, Judge. Tonja Haddad -- 11 THE COURT: Let me just stop you and ask you, 12 is this something I can do on an 8:45, it seems 13 like a lot? 14 MS. COLEMAN: No, Your Honor, it's not. 15 THE COURT: Okay. 16 MS. COLEMAN: It is my motion on behalf of 17 Mr. Epstein. And since the date it was filed I 18 have sent repeated requests to Mr. Scarola's office 19 asking for a specially set date upon which he was 20 available to argue our motion. 21 THE COURT: All right. 22 MS. COLEMAN: Mr. Scarola refused to provide 23 us dates and instead unilaterally set it before 24 this court today. What was originally set before 25 this court today was an issue related to our WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108132  1 discovery which I think would be more germane to 2 the issues since you denied our protective order 3 last Thursday. There is no way this can be heard 4 in five minutes without belaboring the point. And 5 we would respectfully request that since 6 Mr. Scarola's office is not cooperating that you 7 would provide a specially-set date upon which we 8 can argue our Motion to Dismiss in a corporated 9 memorandum of law. 10 MR. SCAROLA: May I have my five minutes to 11 convince you otherwise? 12 THE COURT: Let me just say, I generally don't 13 give dates for counsel. I don't get involved in 14 scheduling. What I generally do is say you 15 schedule it within a certain period of time, if you 16 don't I'll schedule it. But Yes, sir. 17 MR. SCAROLA: Thank you. May I approach the 18 bench? 19 THE COURT: Yes, sir. 20 MR. SCAROLA: Thank you. 21 Your Honor, this is our fourth amended 22 complaint. And the fourth amended complaint makes 23 two changes from the third amended complaint which 24 was the subject of multiple challenges all of which 25 were denied. Those two changes appear in the WWW.USLEGALSUPPORT.COM 561—835-0220 EFTA01108133  5 1 wherefore clause as to count one, and the wherefore 2 clause as to count two. Both of the changes are 3 identical. The prior complaint said that we 4 reserved leave to assert a claim for punitive 5 damages upon satisfying the statutory 6 prerequisites. The amendment says 7 counter-plaintiff Edwards, having satisfied the 8 statutory prerequisites for the assertion of a 9 claim for punitive damages and having been granted 10 leave of court to assert such a claim does hereby 11 also assert a claim for punitive damages. The 12 factual allegations of this complaint remain 13 absolutely unchanged from the repeatedly, 14 unsuccessfully challenged third amended complaint. 15 The Motion to Dismiss before Your Honor is 16 nothing more than a motion for a reconsideration of 17 Your Honor's having granted the leave to assert a 18 claim for punitive damages. And the concept that 19 it is necessary after having satisfied the 20 statutory prerequisites to again argue all of the 21 same legal issues that are being asserted once more 22 that have previously been denied and to wait for 23 special set hearing in order to do that, I suggest 24 to Your Honor, is simply a transparent attempt at 25 further delaying getting this 2009 case set for WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108134  1 trial. That's the reason why I have been insistent 2 upon dealing with this matter at an 8:45 hearing, 3 because I firmly believe that when Your Honor takes 4 a look at this complaint you will find that that is 5 the only change and it does not warrant a special 6 set hearing after Your Honor has already granted 7 leave to amend to assert a claim for punitive 8 damages. 9 Just so that it is clear what has happened 10 here, I have highlighted on both the copy I 11 provided to Your Honor and the copy for opposing 12 counsel each of the factual allegations that were 13 supported by record evidence that allowed Your 14 Honor to grant leave to assert the claim for 15 punitive damages. No new factual allegations have 16 been added to those that formed the basis to assert 17 the claim for punitive damages to begin with. So 18 that's the reason why I have asked Your Honor to 19 deal with this at an 8:45, so that we can finally 20 get a trial date in this 2009 case. 21 Thank you, sir. 22 THE COURT: Yes, ma'am. 23 MS. COLEMAN: Your Honor, before I respond to 24 that, respectfully I'm asking am I going to be 25 compelled to argue my motion in this five minute WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108135  1 hearing? 2 THE COURT: Well, I'll tell you what I'm going 3 to do, I'm going to look at it, so if you want tc, 4 you know -- 5 MS. COLEMAN: Then I will -- 6 THE COURT: Go ahead. 7 MS. COLEMAN: Go ahead. I'm sorry. 8 THE COURT: We got more than five minutes. 9 MS. COLEMAN: My position is as follows, 10 respectfully Mr. Scarola's opinion is just that. 11 His opinion of course of his complaint is that it's 12 fine, there is nothing wrong. Our position is in 13 drast contravention to Mr. Scarola's opinion Th, 14 law, in our opinion, and as proved by our 15 voluminous notebook with which you've been 16 provided -- and for the record, we've provided over 17 two hundred pages of documentation to Judge Crow in 18 support of our Motion to Dismiss. The legal 19 standard for pleading punitive damages under rule 20 1 -- I'm sorry. I completely lost the paper that 7 21 was looking at. But the rule to plead special 22 damages. I believe it's 1.210 or 1.200. It's in 23 our motion -- requires heightened pleadings. So 24 by -- just as an example to give Judge Crow, by his 25 own admission Mr. Scarola has virtually changed WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108136  1 nothing in his complaint. That assertion by its 2 very nature clearly goes to the fact that the 3 complaint has not properly been amended to add a 4 claim in punitive damages. 5 And I apologize to the court, the special 6 pleading requirement statute is 1.120(G) and 768.72 7 of the Florida statutes, require different 8 pleading. 9 THE COURT: So let me stop you and make sure I 10 understand you. What you're saying is that even 11 though I may have given permission based upon the 12 proffer made at the time of the hearing to plead 13 punitive damages you still have to plead sufficient 14 ultimate facts to establish punitive damage 15 liability -- 16 MR. SCAROLA: Yes, Your Honor, and the case 17 law clearly supports that and based upon my 18 communications with Mr. Scarola I realized that 19 this was going to be a problem that could not be 20 addressed in five minutes. We were going to need 21 to convince you otherwise, which is again why I'm 22 requesting that you allow us more time to argue 23 this, because it's a very important issue, 24 obviously. 25 THE COURT: How much time do you need to WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108137  1 argue? 2 MS. COLEMAN: I need at least 20 minutes to 3 argue my point, Judge. 4 THE COURT: I don't give 40 minute hearings. 5 I only have 30 minute hearings. 6 MS. COLEMAN: 15, I can do it in 15. 7 THE COURT: Go ahead. 8 MS. COLEMAN: You want me to argue it right 9 now? 10 THE COURT: I have 15 minutes. 11 MS. COLEMAN: I don't have all the case law 12 with me right now. We were set on a five minute 13 hearing. I was coming in here to request that you 14 give us a specially set hearing, Judge. If you're 15 going to compel me to go forward at this exact 16 moment -- 17 THE COURT: Is the hearing about the stuff 18 I've got in front of me? You know, I'm pretty 19 familiar with the case law in which you've cited 20 here. These are all standard cases. These are not 21 unique. And so what I really want to know is what 22 the factual predicate is for your motion. The case 23 law is very clear. I understand the case law. I 24 don't think you got any new case law in here, do 25 you? WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108138  1 MS. COLEMAN: Any new case law from what, 2 Judge? I don't know what's been submitted to you 3 in the past. 4 THE COURT: In support of your motion. 5 MS. COLEMAN: In support of my motion, no, I 6 filed it on the 18th. 7 THE COURT: No, I mean, any recent cases that 8 have changed the law in any manner. There is 9 nothing new in the case law. What you're really 10 doing is the case law as it applies to the 11 allegations of this complaint presumably is what 12 you're saying. 13 MS. COLEMAN: Yes, I am, Judge. 14 THE COURT: Okay. So tell me what's wrong 15 with this complaint. 16 MS. COLEMAN: I'm just -- 17 Are you making us do this argument now? 18 THE COURT: I'm not making you do anything 19 now. I'm sitting here, I got the thing in front 20 me. I said maybe we can argue it now. You're 21 telling me you're not prepared to argue the motion? 22 Is that what you're saying? 23 MS. COLEMAN: I was prepared for a five minute 24 hearing and I'm telling you, yes, I would prefer 25 to -- WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108139  11 1 THE COURT: Is it something in addition to 2 what's in your memorandum that you want to tell me? 3 MS. COLEMAN: With the case law? No, Judge, I 4 would like to be forwarded the opportunity to 5 properly prepare and argue my point. I've been in 6 your courtroom many, many times as you know -- 7 THE COURT: I'm just asking a simple question. 8 Is there something more than what you've outlined 9 very articulately in the memorandum of motion that 10 you need to argue or can I read it and understand 11 it? 12 MS. COLEMAN: I'm confident you can read it 13 and understand it, Judge, but respectfully, the 14 last couple of times we've been in here and we have 15 not been permitted to outlay our argument, for 16 example, the Motion for Protective Order, which v - 17 tried to get specially set for 15 minutes and 18 Mr. Scarola would not agree, we get ruled against. 19 I'm trying to do my job here. I'm trying to 20 adequately present my client's position. I feel we 21 have a very strong Motion to Dismiss. I'm asking 22 this court to allow us the 15 minutes within which 23 to argue it and to not permit I don't know - I 24 don't have an -- 25 THE COURT: When will you be ready to argue? WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108140  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 here 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 -- WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108141  1 Can you do it at 8:00 in the morning? You 2 generally don't have things scheduled at 8:00 in 3 the morning. 4 MS. COLEMAN: Yes, sir, we have done that 5 before. 6 MR. SCAROLA: The only day that 8:00 would b, 7 a problem would be Wednesday, because I'm scheduled 8 to be on a plane to Tampa Wednesday morning at 9 7:00. 10 THE COURT: How about Monday the 11th, 8:00? 11 MS. COLEMAN: I can do that. 12 THE COURT: All right. Somebody notice it. 13 Okay. 14 MS. COLEMAN: Judge, if you do have the time 15 now -- 16 THE COURT: We can do it at 8:15, too. 17 MS. COLEMAN: That's fine. That's fine with 18 me, Judge. 19 THE COURT: 8:15. That will be better. 8:15 20 on Monday February the 11th. 21 MS. COLEMAN: Thank you, Judge. 22 If you would like to address one small issue 23 now that Mr. Scarola and I both agreed if we had 24 time we would prefer that you address. 25 You denied our Motion for Protective Order WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108142  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 10 file for it. 11 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 15 of that. However, you did not provide in your 16 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 our responses to his discovery -- 23 THE COURT: I don't remember what the 24 financial requests were right now. 25 MS. COLEMAN: Voluminous, over five years of WWW.USLEGALSUPPORT.COM 561—835-0220 EFTA01108143  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 8 more than 30 days. I had suggested at the time of 9 the hearing that Your Honor should include a time 10 for response, because I anticipated this problem 11 and I requested ten days. There was no time for 12 response included in the order and opposing counsel 13 has said I want 30 days from the entry of the order 14 denying my motion for protective order, which would 15 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, 23 that discovery response be submitted. That's the 24 request I made. 25 There is an ancillary issue. And if I :(.1; WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108144  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 it's 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 WWW.USLEGALSUPPORT.COM 561—835-0220 EFTA01108145  1 if I have to. I haven't had an opportunity to 2 review it yet, much less send it to my client or my 3 co-counsels -- 4 THE COURT: Well, what it is is a bullet point 5 of exactly what I said. 6 MS. COLEMAN: I understand what it is, Your 7 Honor, but -- 8 THE COURT: Well, is there something you want 9 more than in my order? 10 MS. COLEMAN: I haven't read it. Yes, Judge, 11 there -- no, I would like to have it say what you 12 say in your order, but there may be -- 13 This is our protective order, Your Honor. 14 This is to protect Mr. Epstein, my client. While I 15 appreciate Mr. Scarola's constant opinions of the 16 law and what should be submitted, it's my client. 17 I should at least at a minimum have a right to 18 review it and edit it if I believe it's necessary. 19 I'm not adding -- I don't anticipate adding 20 anything that the court hasn't delineated in its 21 order, but I think it's incumbent upon me as 22 counsel of record for Mr. Epstein to at a minimum 23 be able to review a confidentiality order that's 24 going to order by Mr. Scarola's own constant words, 25 a billionaire, to disclose all of his financial WWW.USLEGALSUPPORT.COM 561—835-0220 EFTA01108146  1 information absent, you know, something being in 2 place that we need to review. And especially given 3 the situation of what's going on in other 4 litigations between these parties. 5 THE COURT: Well, I guess what I'm asking 6 is -- I mean, I outlined everything that I thought 7 was necessary in my order. And what I'm asking - 8 certainly you've read my order. 9 MS. COLEMAN: I've read your order, Judge. 10 have not 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 Honcr . 25 THE COURT: Have a great day. WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108147  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. WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108148  1 MS. COLEMAN: Thank you, Judge. 2 MR. SCAROLA: And I would respond to that if I 3 had any idea at all what she just said. So I have 4 no response. 5 THE COURT: Excuse me? 6 MR. SCAROLA: I said I would respond to that 7 if I had any idea at all what it is she just said, 8 but I don't. 9 THE COURT: Thank you. 10 MR. SCAROLA: Thank you, Your Honor. 11 THE COURT: Have a great day. 12 MR. SCAROLA: And you too, sir. 13 (Proceedings concluded at 9:18 a.m.) 14 15 16 17 18 19 20 21 22 23 24 25 WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108149  1 CERTIFICATE OF REPORTER 2 3 4 I, Sara Storey, Florida Professional 5 Reporter, State of Florida at Large, certify that I wa 6 authorized to and did stenographically report the 7 foregoing proceedings and that the transcript, page 1 8 through 20, is a true and complete record of my 9 stenographic notes. 10 11 Dated this 4th day of February 2013 in Palm 12 Beach County, Florida. 13 14 15 16 17 18 19 CA&CA Ate`cy Sara Storey, 20 Florida Professionsij Reporter 21 22 23 24 25 WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108150  Page 1 A asserted5:21 clause5:1,2 10:18 11:1,7,22 ability12:14 assertion5:8 8:1 clear6:9 9:23 11:25 12:4,11,14 able12:9 17:23 attemptS:24 16:14 clearly8:2,17 12:17,20 13:10 absent18:1 authorized21:6 client 17:2,14,16 13:12,16,19 14:2 absolutely 5:13 available3:20 client's11:20 14:7,23 15:2,6 add8:3 a.m1:16,16 20:13 COLEMAN3:3,7,14 16:2,5 17:4,8,20 added6:16 3:16,22 6:23 7:5 18:5,12,22,25 B 7:7,9 9:2,6,8,11 19:4,20,23 20:5 adding17:19,19 addition11:1 back16:25 10:1,5,13,16,23 20:9,11 18:14 based8:11,17 11:3,12 12:1,7 Courthouse1:17 address 13:22,24 basically14:7 12:13,18 13:4,11 courtroom 1:17 addressed8:20 19:6 13:14,17,21 14:3 11:6 adequately 11:20 basis6:16 14:9,25 16:23 co-counsels17:3 admission :25 Beach1:2,17,18 17:6,10 18:9,16 Crow1:14 7:17,24 afternoon18:17 2:8,8 21:12 19:2,12 20:1 behalf2:2,7 3:16 coming 9:13 D agree11:18 agreed13:23 14:18 belaboring4:4 communications D3:1 16:11 19:18 believe6:3 7:22 8:18 damage 8:14 ahead7:6,7 9:7 14:4 15:16 16:17 compel 9:15 damages 5:5,9,11 12:20,22 17:18 compelled6:25 5:18 6:8,15,17 al2:7 believed16:7 complaint 4:22,22 7:19,22 8:4,13 allegations 5:12 bench4:18 4:23 5:3,12,14 15:5 6:12,15 10:11 better13:19 6:4 7:11 8:1,3 date3:17,19 4:7 allow8:22 11:22 beyond15:22 10:11,15 6:20 14:16,18,21 19:10 billionaire 17:25 complete21:8 19:3 allowed6:13 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9:1,3,8 10:20,21 CERTIFICATE 21:1 17:22 depositions 12:8 11:5,10,23,25 certify21:5 count 5:1,2 different8:7 12:6 challenged5:14 counter-plaintiff 14:14 19:11 argument10:17 challenges4:24 5:7 disagreed14:20 :15 change6:5 County 1:2,17,18 disclose17:25 arises19:14 changed7:25 10:8 21:12 discovery4:1 articulately11:9 changes4:23,25 couplo11:14 14:17,22 15:4,16 asked6:18 5:2 course 7:11 15:20,23 16:14 asking3:19 6:24 CIRCUIT1:1,1 court1:1 3:6,11 19:2 11:7,21 18:5,7 circumstances 15:4 3:15,21,24,25 discuss18:18 18:12 19:20 cited9:19 4:12,19 5:10 Dismiss4:8 5:15 assert 5:4,10,11 claim5:4,9,10,11 6:22 7:2,6,8 8:5 7:18 11:21 5:17 6:7,14,16 5:18 6:7,14,17 8:9,25 9:4,7,10 Dixie1:17 8:4 9:17 10:4,7,14 docket 14:3 WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01108151  Page 2 documentation 7:17 7:8 8:20 9:12 Honor3:14 4:21 leave5:4,10,17 3:1 10:23 14:25 5:15,24 6:3,6,11 6:7,14 doIng10:10 FL2:4,8 6:14,18,23 8:16 legal 5:21 7:18 drafted16:8 18:21 Florida1:2,18,22 15:3,9 16:1,4,6 19:14 19:16,22 8:7 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