EFTA01110876.pdf

TONJA HADDAD, PA 315 SE 7th Street telephone Suite 301 Fort Lauderdale, FL 33301 August 29, 2013 Via Electronic Mail Jack Scarola, Esq. Searcy Denney et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Re: Epstein v. Edwards et at Mr. Scarola: Enclosed please find Mr. Epstein's Motion, pursuant to § 57.105 of the Florida Statutes, which we will file in the timeframe proscribed by the aforementioned Florida Statute should your client not immediately dismiss this action against Mr. Epstein, with prejudice. While the grounds for the Motion are delineated therein, please note that you are, and have been, on notice of the invalidity of this suit, as your Counterclaim against Mr. Epstein is neither supported by the material facts nor the application of existing law to those facts. While we are aware that our predecessor counsel has served these letters and motions upon you before, the fact that Mr. Edwards's Counterclaim cannot stand is further supported by the recent decision in Wolfe v. Foreman, 38 FLA. L. WEEKLY D1540 (July 17, 2013), in which the court conducts a detailed analysis of the law applicable to both of Mr. Edwards's causes of action, and unequivocally reaches the same undeniable conclusion; there is no cause of action. A copy of the decision is enclosed herewith for your reference and consideration. I am hopeful that you and your client can objectively examine this case and its applicability to your pleadings, the facts upon which you rely therein, and the applicable case law, so that you can suitably assess your position. Sincerely, TONJA HADDAD. PA Tonja Haddad Coleman, Esq. for the firm cc: Bradley Edwards, Esq. EFTA01110876