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EFTA00612483

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IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Bradley J. Edwards. The trial judge relied in part upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court issued its decision in Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), declining to follow Wolfe and EFTA00612483

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