EFTA01080992.pdf

1 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN 2 AND FOR PALM BEACH COUNTY, FLORIDA 3 CASE NO.: 502009 CA 040800XXXMBAG 4 JEFFREY EPSTEIN, 5 Plaintiff, 6 vs. 7 SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, 8 and L.M., individually 9 Defendants. 10 11 12 HEARING BEFORE: THE HONORABLE DAVID F. CROW 13 DATE TAKEN: Wednesday, September 28, 2011 14 TIME: 8:15 a.m. - 8:45 a.m. 15 PLACE: Palm Beach County Courthouse 205 North Dixie Highway 16 West Palm Beach, Florida 33401 17 REPORTED BY: BARBARA L. KENT, RMR, RPR, FPR, CSR-MI Court Reporter and Notary Public 18 19 20 21 22 23 24 25 ORANGE REPORTING 800.275.7991 EFTA01080992  1 APPEARANCES 2 JOSEPH L. ACKERMAN, JR., ESQUIRE CHRISTOPHER E. KNIGHT, ESQUIRE 3 OF: Fowler, White, Burnett, P.A. 4 5 6 APPEARING ON BEHALF OF THE PLAINTIFF, 7 JACK SCAROLA, ESQUIRE OF: Searcy, Denney, Scarola, Barnhart & Shipley 8 9 10 APPEARING ON BEHALF OF BRADLEY J. EDWARDS. 11 12 ALSO PRESENT: Bradley J. Edwards. 13 14 15 16 17 18 19 20 21 22 23 24 25 ORANGE REPORTING 800.275.7991 EFTA01080993  3 1 PROCEEDINGS • * * * 2 3 THE COURT: Okay. Have a seat, please. 4 We're here on Epstein versus Rothstein, and 5 it's the Motion to Dismiss. I guess, the second 6 point, as well as your new Motion for Punitive 7 Damages. 8 I have read the motions. I have read all the 9 cases you guys provided to me, and I have read 10 them, too, when they were submitted to me earlier, 11 at least most of them. 12 So I think we should deal with the Motion to 13 Dismiss, first. 14 So, I guess, that is your motion. 15 Mr. Scarola. 16 MR. SCAROLA: Thank you, Your Honor. 17 With the Court's permission, may I address 18 the Court from counsel table? 19 THE COURT: That's fine, yes. Certainly. 20 MR. SCAROLA: Thank you very much. 21 Your Honor, what I think will be most helpful 22 is, if we went through the second amended complaint 23 and addressed what that complaint does or does not 24 do in some detail. 25 Obviously, the introduction, which is ORANGE REPORTING 800.275.7991 EFTA01080994  4 1 unnumbered, and does not constitute any of the 2 allegations against Mr. Edwards, is nothing more 3 than a press release incorporated into a pleading, 4 for purposes of cloaking it in litigation, in 5 unity. I think we can effectively ignore it. 6 The first five numbered paragraphs are, 7 basically, jurisdictional, and then paragraphs six, 8 seven, eight, nine, ten, 11, 12, 13, 14, all the 9 way through paragraph 22, are paragraphs that 10 describe in substantial detail the uncontested 11 misconduct of Scott Rothstein, and his involvement 12 in a Ponzi scheme. 13 Paragraph 21 alleges that Mr. Edwards was 14 aware that RRA's offices were monitored and 15 recorded various discussions. Obviously, that is 16 immaterial to any claim of abusive process. And 17 paragraph 22 talks about the level of 18 communications going on within the firm, relating 19 to the prosecution of what clearly was, and 20 continued to be, an extremely important case within 21 the firm. 22 The substantive allegations on which I 23 suggest we must focus, to the extent there's any 24 substance in them at all, begin at paragraph 23. 25 And that paragraph says that, that there were a lot ORANGE REPORTING 800.275.7991 EFTA01080995  5 1 of e-mails that went back and forth with regard to 2 the prosecution of this -- these major pending 3 cases within the law firm. There is nothing about 4 that exchange of e-mails that would suggest 5 Mr. Edwards' knowledge of, or involvement in an 6 Ponzi scheme. 7 Paragraph 24 describes a variety of events 8 that clearly have, from Mr. Edwards' perspective, 9 an entirely innocent explanation, and dove-tie him 10 into that Ponzi scheme. But as we're going to see, 11 even if Mr. Edwards were tied into the Ponzi 12 scheme, that's got nothing to do with any damage 13 suffered by the plaintiff, Mr. Epstein. 14 Paragraph 25 says that, given the 15 interdependence of so many RRA lawyers, 16 investigators, and other staff, the wide 17 communications that necessarily accompanied the 18 involvement of so many people, Edwards knew or 19 should have known, there was a Ponzi scheme going 20 on. 21 Well, that clearly is a conclusion that is 22 based upon the pyramiding of a variety of 23 inferences, and is not a reasonable conclusion, 24 based upon the preceding allegations about nothing 25 more than an exchange of e-mails and meetings going ORANGE REPORTING 800.275.7991 EFTA01080996  1 on, none of which, Edwards is alleged to have been 2 involved in, in terms of the -- the attempt to sell 3 investments. 4 Then we get to paragraphs 26, 27, and 28, and 5 we're back to Mr. Rothstein, again. And now we 6 have the abusive process claim against Mr. Edwards. 7 In paragraph 30, we learned that on 8 September 11, 2008, Mr. Edwards filed a state court 9 action on behalf of a client seeking damages. Now, 10 we know that those were legitimate claims. There's 11 no allegation anywhere in this complaint that they 12 were anything other than well-founded legitimate 13 claims. 14 30 B says that there was a federal court 15 complaint that was filed against somebody with a 16 different name, that because it was filed against 17 somebody with a different name, Mr. Epstein never 18 learned about it. Because not only was it filed 19 against somebody with a different name, it was 20 never served, according to the allegations in the 21 complaint on Mr. Epstein. 22 Now, clearly, there can be no abuse of 23 process, and no damages arising out of a complaint 24 against someone else with a different name that is 25 never served on this plaintiff. ORANGE REPORTING 800.275.7991 EFTA01080997  7 1 Then we have allegations in 30 C, that state 2 what Mr. Epstein believes about the federal 3 complaint; and he believes that it was filed to 4 show to prospective Ponzi scheme investors. Well, 5 again, assuming those -- assuming that belief to be 6 accurate, and a belief is not an allegation of 7 fact, except as to the subjective understanding of 8 Mr. Epstein. It doesn't say, this is what did 9 occur, it says that's what Mr. Epstein believed 10 occurred. 11 Even assuming that to be the case, the filing 12 of a federal court action to show to somebody else, 13 to defraud someone else, clearly cannot produce 14 damages to Mr. Epstein. And, in fact, when we get 15 to the damage allegations, the only allegation of 16 damages are, that Mr. Epstein was obliged to pay 17 attorney's fees to defend against state court 18 actions taken in the prosecution of the filed and 19 served state court claim. So there can be no 20 causal connection between what is alleged in 21 paragraph 30 C, and any damages to Mr. Epstein. 22 Now, the same is true when we get to 23 paragraph 32. Edwards also made illegal, improper, 24 and perverted use of civil process in order to 25 bolster the case to investors by using it to ORANGE REPORTING 800.275.7991 EFTA01080998  8 1 conduct unreasonable and unnecessary discovery, 2 making unfounded allegations, and we're going to 3 get to that. That clearly can't be the federal 4 court case, because the federal court case is never 5 served. So we must be talking about the state 6 court case, and paragraph 31 makes reference to the 7 state court case. 8 Then, we take a look at what it is that 9 Mr. Edwards is alleged to have done, that 10 constituted abuse of process. And we go to 11 subparagraphs one through ten, about actions 12 alleged to have been taken directly in the state 13 court action during the course of the prosecution 14 of the state court action, that are alleged to have 15 caused Mr. Epstein to spend money on attorney's 16 fees to defend against those actions alleged to 17 have been directly involved in the prosecution of 18 the state court claim. 19 Now, there is an allegation in paragraph 33 20 that Mr. Edwards had ulterior motives. 21 Significantly, there is no allegation that these 22 "ulterior" motives were the sole motives involved 23 in all of the actions described in paragraph 32. 24 And these ulterior motives are maintaining a Ponzi 25 scheme, of which Mr. Epstein was never, and could ORANGE REPORTING 800.275.7991 EFTA01080999  9 1 not have been a victim, because he didn't know 2 about it. So, that's got no relevance, and it's 3 not alleged that it was the sole motive. 4 And then there are two other very curious 5 motives alleged; obtaining funds for the continued 6 investigation and prosecution of the Epstein 7 actions, and obtaining operating revenues so that 8 RRA could continue to operate. 9 Now, I don't know how the plaintiff's law 10 firm business is conducted, but there isn't any law 11 firm that I'm aware of, that doesn't engage in the 12 practice of law for purposes of obtaining funds to 13 investigate and prosecute other cases; or to obtain 14 operating revenue so that the firm could continue 15 to operate. I don't know how that constitutes some 16 form of improper motive, that you are in business 17 to make a profit, and to continue to be able to 18 fund other cases to make profits. 19 So those allegations, even if they were 20 allegations that those were the sole motives, are 21 not allegations of some malicious and improper 22 motivation. 23 That's where the allegations of wrongdoing 24 end, and then paragraph 34 is the -- is the damage 25 paragraph, as a result of Mr. Edwards doing all of ORANGE REPORTING 800.275.7991 EFTA01081000  10 1 these things to prosecute his legitimate claims. 2 It is alleged that the plaintiff suffered damages 3 by incurring additional and unnecessary attorney's 4 fees. 5 There are four cases that are entirely 6 dispositive of this third attempt to try to 7 fabricate some justification for the extortion 8 attempt that Mr. Epstein began back in 2009, and 9 continues to pursue today. 10 The first of those is, SI Investments versus 11 Payless Flea Market, it appears at tab 18 in the 12 notebook that Your Honor was provided by the 13 defendants. You might just make 14 THE COURT: Okay. Because I didn't see any 15 cases, other than the litigation for those cases 16 cited in your motion. 17 MR. SCAROLA: Your Honor, the Motion to 18 Dismiss incorporates the legal authorities that are 19 described in detail in the Motion to Assert a Claim 20 for Punitive Damages, and all of these cases are 21 cited by both parties. 22 So, SI Investments stands for the following 23 propositions, and these are quotes. Plaintiff must 24 prove that the process was used for an immediate 25 purpose other than that for which it was designed. ORANGE REPORTING 800.275.7991 EFTA01081001  11 1 Where the process was used to accomplish the result 2 for which it was intended, regardless of an 3 incidental or concurrent motive of spite or 4 ulterior purpose, there is no abusive process. 5 That's the case the defendants themselves are 6 relying upon. 7 So if you have two motives, one's a good one, 8 because what you want to do is, you want to recover 9 damages against Mr. Epstein for his serial abuse of 10 young children. If you have -- 11 THE COURT: Well, isn't the -- isn't the 12 distinction, or as I understand it, correct me if 13 I'm wrong, but the -- while the initial process may 14 be for profit purpose, the issue on abuse of 15 process is something occurring subsequent. Even 16 though it may be filed for legitimate purpose, the 17 abuse process occurs, as compared to malicious 18 prosecution when it's filed for an improper 19 purpose; right? 20 MR. SCAROLA: In order for an abusive process 21 claim. 22 THE COURT: Right. 23 MR. SCAROLA: To be based upon an initial 24 filing. 25 THE COURT: Right. ORANGE REPORTING 800.275.7991 EFTA01081002  12 1 MR. SCAROLA: It must be demonstrated that 2 the sole purpose was an improper purpose. And the 3 case law is, that subsequent use of process where 4 there is a concurrent legitimate purpose, does not 5 constitute an abuse of process. That's the Fourth 6 DCA, 2010 recent law, that clearly describes the 7 scope of an abuse of process claim and the elements 8 involved. 9 THE COURT: Well, it also says, the mere 10 filing of a complaint having process served is not 11 enough to show abusive process. The plaintiff must 12 prove improper use of the process after it issues. 13 MR. SCAROLA: Yes, sir, that's correct. 14 THE COURT: Okay. 15 MR. SCAROLA: Okay. And that's what they 16 attempt to do, when they lay out in paragraph 32, 17 all of these alleged improper uses of the 18 litigation. 19 THE COURT: Where -- where -- I mean, I don't 20 mean to cut you off, but I mean you're running 21 short of time here, and, you know, if we started 22 right on time -- but I do have to give them an 23 opportunity. 24 You said this is the dispositive -- SI 25 Investments is dispositive. I thought you were ORANGE REPORTING 800.275.7991 EFTA01081003  13 1 going to talk about damages, but is there something 2 about damages in here? 3 MR. SCAROLA: There are. Your Honor, there 4 are four cases, which together, I suggest are 5 diapositive. 6 THE COURT: Give me the names of them, 7 because I want to read them. 8 MR. SCAROLA: Yes, sir. 9 The next case, and I will hand Your Honor a 10 copy of these others. 11 THE COURT: Are they all in the book here? 12 MR. SCAROLA: They are. Two of them are in 13 the book, I think the third one is, as well. 14 THE COURT: Okay. 15 MR. SCAROLA: Tab number four 16 Levin-Middlebrook is tab number 18. 17 THE COURT: Gotcha. I've read that 1,000 18 times. 19 MR. SCAROLA: Yes, sir, I'm sure you have. 20 And -- 21 THE COURT: You can give it to me, again, 22 though. 23 MR. SCAROLA: I will be happy to do that. 24 THE COURT: Yeah. This deals with litigation 25 privilege. ORANGE REPORTING 800.275.7991 EFTA01081004  14 1 MR. SCAROLA: Yes, sir. It does deal with 2 litigation privilege. Echevarria also deals with 3 the litigation privilege, and Delmonico stands for 4 the proposition that the issues with regard for 5 privilege, are issues of law for the court to 6 determine. 7 And I've provided Your Honor with highlighted 8 copies, I'm providing opposing counsel with 9 highlighted copies, as well. 10 THE COURT: Okay. 11 MR. SCAROLA: The basic point here is, Your 12 Honor, that the litigation privilege is an absolute 13 privilege. Once it is established that the actions 14 occur within the course and scope of the 15 litigation, the privilege applies absolutely as a 16 matter of public policy. 17 The basis of those decisions is, that if 18 there's misconduct in the course of the litigation, 19 if you're taking improper discovery, if you're 20 filing improper motions, there are remedies that 21 are available to the court through the court's 22 inherent power to control its own litigation, 23 through the contempt powers of the court, through 24 Florida Statute 57.105, and through the filing of 25 bar grievances, and it will cripple the system, if ORANGE REPORTING 800.275.7991 EFTA01081005  15 1 litigants are obliged to respond to separate 2 litigation, just because somebody is alleged, you 3 notice the deposition that shouldn't have been 4 noticed, you filed a motion that shouldn't have 5 been filed. 6 THE COURT: Are you saying it's a matter of 7 law, there can be no abuse of process by an 8 attorney, then? 9 MR. SCAROLA: No, sir. I'm not saying as a 10 matter of law there can be no abuse of process by 11 an attorney. 12 THE COURT: Just the -- 13 MR. SCAROLA: Because if there -- because the 14 test is, it must be related to the litigation. So, 15 if I were to issue a subpoena to my next-door 16 neighbor in a pending case, just because I want to 17 inconvenience him and bring him down to the 18 courthouse, knowing that he just moved to Florida 19 two weeks ago, and this case involves an automobile 20 accident that occurred three years ago, that he 21 couldn't absolutely know anything about, that would 22 be an abuse of process. 23 THE COURT: Here's my question. 24 MR. SCAROLA: Yes. 25 THE COURT: Whether or not that litigation -- ORANGE REPORTING 800.275.7991 EFTA01081006  16 1 and generally speaking, a privilege is an 2 affirmative defense. Whether or not something is, 3 or is not within the process, or within the 4 lawsuit, and falls within the immunity, is 5 certainly something that the judge will have to 6 decide rather than the jury. But it may be 7 dependent on specific facts under specific 8 circumstances, may it not? 9 MR. SCAROLA: It may be. 10 THE COURT: Okay. But you're saying, as a 11 matter of law -- I'm sorry. 12 MR. SCAROLA: I am sorry. I didn't mean to 13 interrupt the Court. 14 THE COURT: I guess what you're saying, it's 15 a matter of law, these allegations are such that I 16 can determine from the law -- looking at the 17 pleadings themselves, that it falls within the 18 privilege? 19 MR. SCAROLA: First, absolute privilege, as 20 distinguished from qualified privilege. Qualified 21 privilege is -- almost always involves questions of 22 fact, but this is an absolute privilege. And 23 secondly, you can determine from the face of the 24 complaint, that this was related to the litigation 25 itself. ORANGE REPORTING 800.275.7991 EFTA01081007  17 1 THE COURT: Okay. 2 MR. SCAROLA: You can see that on the face of 3 the complaint. 4 THE COURT: Okay. 5 MR. SCAROLA: So that's the basis of -- of 6 this dismissal argument, and the -- the allegations 7 of the nature of the damages that were incurred, as 8 well. 9 The nature of the damages are, I had to incur 10 attorney's fees in the context of this litigation. 11 THE COURT: Yes, sir. 12 MR. ACKERMAN: Your Honor, it's our position 13 that the corrected second amended complaint 14 satisfies on its four corners, every element of the 15 tort of abuse of process. 16 We have alleged a misuse of the judicial 17 system through a legal, improper, perverted use of 18 process. We have set those examples out. 19 We have alleged in the complaint, that they 20 were for ulterior purposes, not intended by the 21 law, after the action was, that resulted in 22 damages. We can clearly show that, by looking at 23 paragraph 30 A-C, when the LM case is filed in 24 state court against Mr. Epstein, and it is pending 25 for some time, that this 234-page, 156-count ORANGE REPORTING 800.275.7991 EFTA01081008  1 complaint is filed in Federal Court seeking in 2 excess of $23 million in damages, and it was 3 against Mr. Epstein. We can prove that. And was 4 intended there, we believe, with highly charged 5 allegations, to assist Mr. Rothstein in attracting 6 investors to invest in the Epstein cases. 7 Mr. Epstein's damages include filing motions 8 to dismiss that. That occurred approximately nine 9 months later. So, on that -- on its face, that is 10 a process that is issued after LM, involving the LM 11 case. 12 We then proceeded to list 32 separate 13 instances of abuse of process, and not all of them 14 are in the state cases, a couple are in the federal 15 cases. 16 Paragraph 33 alleges the motives, and we 17 believe that Mr. Edwards was attempting to assist 18 Mr. Rothstein, which is why all the allegations of 19 Mr. Rothstein's conduct with Mr. Edwards' cases, 20 that Mr. Scarola clearly wants to dismiss as 21 unrelated, are appropriate. Because the Court can 22 see on the face of the complaint that there is a 23 link. Mr. Edwards' investigators, Mr. Edwards' 24 cases are ultimately involved with Mr. Rothstein, 25 with the Ponzi scheme. ORANGE REPORTING 800.275.7991 EFTA01081009  19 1 We've also alleged in paragraph 24, and I 2 believe if the Court looks at the 15 e-mails 3 in camera, the Court will see that link; and what 4 Mr. Scarola wants to clearly dismiss as e-mails on 5 a case, is on the day that there is contact with 6 Mr. Rothstein and the investors, Mr. Rothstein 7 extends an e-mail, which we've alleged, to the 8 investors, who subsequently invest in the Epstein 9 cases, which is the purpose we've alleged, not 10 recovering money on a cause of action, that state, 11 here are the causes of action we have against 12 Mr. Epstein. 13 And based on the privileged log information 14 that we've received, you can see Mr. Rothstein 15 asking Mr. Adler, and Mr. Edwards in August, and 16 then again in October, what are the causes of 17 action against Mr. Epstein? On the day that he 18 communicates -- the day that Mr. Rothstein 19 communicates with the investors, there's a series 20 of e-mails that involve Mr. Adler, that involve 21 Mr. Edwards, that involve investigators and other 22 people, contrary to what Mr. Edwards has testified 23 to, that show a clear link that they are providing 24 the information that Mr. Rothstein asked for -- on 25 the causes of action against Mr. Epstein, that he ORANGE REPORTING 800.275.7991 EFTA01081010  20 1 subsequently gives to the investors. 2 Now, it is our position that links 3 Mr. Edwards to Mr. Rothstein's scheme. And that 4 therein, provides the necessary element that we can 5 prove that the actions that were taken, that we've 6 alleged to be an abuse of process, aren't protected 7 by any privilege, and were in furtherance of that 8 scheme, as alleged. 9 We've also alleged special damages. The law 10 is very clear, that if a person has to defend 11 themself against the conduct of another party, that 12 they are allowed to come in in separate litigation 13 and claim those damages as special damages. Those 14 have been specifically pled. And right now 15 everything that Mr. Scarola is arguing, are issues 16 of fact that need to be properly pled as 17 affirmative defenses. 18 THE COURT: Let me understand the damages 19 here. The damages are not the defending the 20 lawsuit, because nowhere in here do you contend 21 that the lawsuits are frivolous or not supported by 22 facts. 23 MR. ACKERMAN: No, the damages -- 24 THE COURT: Let me finish. 25 MR. ACKERMAN: I apologize, Your Honor. ORANGE REPORTING 800.275.7991 EFTA01081011  2 11:23 19:13 CERTIFIED 28:18 contact 19:5 damage 5:12 7:15 basic 14:11 certify 28:6 contempt 14:23 9:24 24:20 basically 4:7 25:8 charged 18:4 contend 20:20 damages 6:9, 23 basis 14:17 17:5 children 11:10 context 17:10 7:14, 16, 21 10:2, be 7:5 16:6 22:22 Christine 27:16 continue 9:8, 14, 17 20 11:9 13:1, 2 be. 16:9 CHRISTOPHER 2:2 continued 4:20 9:5 17:7, 9, 22 18:2, 7 BEACH 1:2, 15, 16 CIRCUIT 1:/, 1 continues 10:9 20:9, 13, 13, 18, 19, 2:4, 8, 8 27:17 28:3 circumstances 16:8 contrary 19:22 23 24:2 25:25 bearing 22:23 cited 10:16, 21 control 14:22 26:16 been 6:1 15:3 civil 7:24 copies 14:8, 9 Damages. 3:7 26:3 began 10:8 claim 4:16 6:6 copy 13:10 27:9 beginning. 23:25 7:19 10:19 12:7 corners 17:14 DATE 1:13 BEHALF 2:6, 10 6:9 20:13 23:6 correct 11:12 23:20 Dated 28:10 belief 7:5, 6 claim. 8:18 11:21 correct. 12:13 21:9 DAVID 1:12 believe 18:4, 17 claimed 22:11 23:21 day 19:5, 17, 18 19:2 21:17 23:20 claims 6:10 corrected 17:13 26:15 28:10 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connection 7:20 CSR-MI 1:17 28:5 23:19 causes 19:11, 16, 25 constitute 4:1 12:5 curious 9:4 determine. 14:6 certainly 16:5 constituted 8:10 cut 12:20 dichotomy 27:6 Certainly. 3:19 constitutes 9:15 did 7:8 28:6 <D> ORANGE REPORTING 800.275.7991 EFTA01081012  5 16:21 17:2, 5, 17 23:2 process. 11:4 reason 21:19 18:18 19:16 25:16, person 20:10 15:22 17:15 21:8 reason. 25:6 21 perspective, 5:8 produce 7:13 reasonable 5:23 offices 4:14 perverted 7:24 products 25:8 received 19:14 Okay 3:3 10:14 17:17 profit 9:17 11:14 reconsidering 26:24 12:15 16:10 21:12, Phillips 2:3 profits. 9:18 record 27:16 28:8 19 22:18 23:22 Phipps 27:16, 16 properly 20:16 recorded 4:15 24:9, 21 25:13, 25 PLACE 1:15 proposition 14:4 recover 11:8 26:17 plaintiff 5:13 10:2, propositions 10:23 recovering 19:10 Okay. 12:14 13:14 23 12:11 prosecute 9:13 reference 8:6 14:10 17:1, 4 22:9, Plaintiff, 1:5 2:6 10:1 regard 5:1 14:4 17 24:5 27:11 plaintiff. 6:25 prosecution 4:19 22:18 24:17 on 6:7 19:4, 24 plaintiffs 9:9 25:11 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Rothstein's 18:19 17:24 10:24 11:1, 13, 15, read 3:8, 8, 9 13:7, 20:3 people 5:18 19:22 /7, 20 12:3, 5, 7, 10, 17 21:20 24:3 26:9 RPR 1:17 28:5 permission 3:17 11, 12 15:7, 10 reading 24:8 25:3 RRA 5:15 9:8 permit 23:3 16:3 17:18 18:10, really 24:12, 24 RRA's 4:14 permitted 21:16 13 20:6 21:6 25:5, 25:14 26:12 ruled 25:1 17, 21, 22 27:5 ORANGE REPORTING 800.275.7991 EFTA01081013  6 ruling 26:8, /5 SI 10:10, 22 12:24 suggest 4:23 5:4 they 6:11 12:/5 running 12:20 sides 24:12 13:4 25:6 17:19 Significantly 8:21 sul 26:24 things 10:1 21:4 <S> sir 12:13 13:19 suit 25:16, 17, 20, think 3:12, 21 4:5 S 2:1 3:1 14:1 15:9 21, 22 13:13 21:1 22:1, 5 satisfies 17:14 sir. 13:8 17:11 supported 20:21 24:11 25:2 saying 15:6, 9 21:3, 11 27:10 sure 13:19 25:16 third 10:6 13:13 16:10, 14 26:23 six, 4:7 27:7 this 25:10 says 4:25 5:14 slap-suit 25:9 system 14:25 17:17 this, 25:3 6:14 7:9 12:9 so 24:13 system. 22:14 Those 20:13 22:19, SCAROLA 2:7, 7 So, 15:14 21 3:/6, 20 10:17 sole 8:22 9:3, 20 <T> though. 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