Filing # 129800478 E-Filed 06/30/2021 11:35:28 AM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI DADE COUNTY, FLORIDA

FAMILY DIVISION

CASE NUMBER: 2020-005358 FC 28

FLORIDA BAR NUMBER: 84857

In Re:

GERI SATIN,

Petitioner/Former Wife,

v.

ERIC SATIN,

Respondent/Former Husband.
_______________________________/

FORMER WIFE’S VERIFIED EMERGENCY MOTION FOR INJUNCTION

COMES NOW the Petitioner/Former Wife, GERI SATIN, by and through her

undersigned attorney, and hereby moves this Court, on an emergency basis, for a

temporary injunction to prohibit the Former Husband from speaking to media or third

parties unrelated to this case about the minor children, and as grounds therefore, would

state as follows:

1. For well over one (1) year now, the Former Husband has engaged in

what can best be described as the most egregious conduct in a domestic relations case.

While the docket clearly reflects the above, a short summary of the Former Husband’s

actions and the results of same within the past year include: accessing attorney-client

privilege communications between the Former Wife and her previous counsel; engaging
in activity that suggests the Former Husband was making up false allegations of sexual

abuse involving himself and the parties minor daughter to create a false narrative that

the maternal grandmother was coaching the child to make said statements; thereafter

suggesting the five years old minor child actually manipulated everyone; sending a new

year’s eve email to the Judge, the Judge’s husband, the Florida Bar, The U.S.

Attorney’s Office, and participants in this case of his conspiracy theory related to the

Miami-Dade Court system; subpoenaing the Judge’s husband for deposition; sending

an email blast to the minor children’s school with not only a description of the details of

this case but also a link to body cam footage from a domestic violence incident; sending

threating text messages to the child’s treating therapist; filing documents in this case

taunting the Guardian ad litem’s attorney about the recent death of her Father;

threatening the Guardian; violating a criminal stay away order; removing approximately

$75,000.00 from a bank account in direct violation of a court order; injunctions being

entered to recapture stolen money; fleeing the jurisdiction for several months to avoid a

psychological evaluation; being held in direct criminal contempt; issuance of multiple

warrants for the Former Husband’s arrest; numerous bizarre posts on social media

regarding this case which include postings of Our Family Wizard communications and

text messages between the Former Husband and the child’s therapist regarding

extremely sensitive topics; seeking out former employers of a supervision company to

further the Former Husband’s conspiracy theory; being belligerent during court

hearings, including, cursing multiple times at the Judge (as recent as June 2, 2021 1),

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See docket # 1049.
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having to be removed from proceedings, smoking cigarettes during hearings,

interrupting attorneys, and disparaging the Guardian ad litem; uncontrolled attacks on

the Guardian ad litem, degrading the Former Wife regarding her physical appearance,

and attacking professionals in this case; taunting very sensitive litigants in other cases

in the same division as this case 2; and filing federal lawsuits against the State of Florida,

the Guardian, and the child’s treating therapist; and three Orders to Show Cause for

indirect criminal contempt that are pending before the Court. If the above was not

enough, the Former Husband decided to amplify his actions by now inviting a

“journalist” to post many of the above topics on the internet. However, of most concern,

and the gravamen of this motion, the Father conducted an interview on this

“journalist’s” website where he discusses the sexual abuse allegations and

mentions his daughter by name! This interview was released one week ago.

2. Consistent with the Former Husband’s highly unusual and erratic behavior

throughout this litigation, the Former Husband has been communicating and fully invited

“journalist” Michael Volpe to participate in these proceedings. At the outset, the Former

Husband asked that Mr. Volpe join mediation between the parties on June 17, 2021 on

grounds that Mr. Volpe will be “closely following the case going forward,” a request

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The Former Husband created an excel spread sheet on numerous cases involving
several law firms and other individuals to further his conspiracy theory. However, there
is one case involving the Guardian’s attorney wherein the Court and all parties involved
worked very hard to assist one of the litigants to rehabilitate so that parent could reunify
with their child. The Former Husband decided to target this extremely fragile person by
filing a background check of that litigant in this case (which contained extremely private
information) and also unnecessarily harassed his counsel and served that litigant with a
subpoena in this case. Soon after the Former Husband engaged in the above, the
litigant was found dead in his home after an apparent overdose.
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which the Former Wife denied. Then, on this past Wednesday, on June 23, 2021, the

Former Husband gave an interview under his full name with Mr. Volpe that was posted

on Mr. Volpe’s website stating that, “Satin said the false allegations continued until the

court settled on a charge that he coached his daughter to say that her mother and her

mother’s family was coaching her to make false allegations against him. This, Satin

said, came shortly after his daughter disclosed to him yet another scheme to try and tag

him with child molestation charges” in reference to the parties’ then five-year-old

daughter. 3 If this were not enough, the Former Husband then gave a video interview

with Mr. Volpe that was posted on Mr. Volpe’s website on Thursday, June 24, 2021, in

which the Former Husband reiterates the above allegations against his daughter, calls

her by name, states her age, the court in which his case is pending, and which again

displays his full name. It would not be difficult to pinpoint the minor child’s identity from

these details, especially because a video is posted just below the article which shows

the Former Wife and the Former Wife’s home where the minor child resides, placing the

minor child’s safety at great risk.

Moreover, in a prior broadcast, Mr. Volpe played what appeared to be an illegally

obtained recording of the supervision company and one of its employees regarding the

parties in this case. Additionally, on June 29, 2021, Mr. Volpe posted on his website a

supervision report from one of the Former Husband’s supervised visits. Thus, the

Former Husband’s release of sensitive information related to the minor children is

rapidly increasing.

3 The child turned six on June 28, 2021.

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 3. Pursuant to Florida Rule of Family Law Procedure 12.605, this Honorable

Court may grant a temporary injunction so long as the moving party has demonstrated:

(1) irreparable harm unless the injunction issues; (2) unavailability of an adequate legal

remedy; (3) a substantial likelihood of success on the merits; and (4) that the public

interest is supported by entry of injunction. Fla. Fam. L.R.P. 12.605. Atomic Tattoos,

LLC v. Morgan, 45 So. 3d 63, 64-65 (Fla. 2d DCA 2010).

4. An order excluding access of the public and press may be made so long

as “cogent reasons” exist for the order. Barron v. Florida Freedom Newspapers, Inc.,

531 So. 2d 113, 118-19 (Fla. 1988). According to the Florida Supreme Court, such

cogent reasons that warrant closure of court proceedings or records include those

necessary “to avoid substantial injury to innocent third parties [i.e. to protect young

witnesses from offensive testimony; to protect children in a divorce]; or… to avoid

substantial injury to a party by disclosure of matters protected by a common law or

privacy right not generally inherent in the specific type of civil proceeding sought to be

closed.” Id. at 118. Certainly, allegations of the Father discussing sexual abuse and

coaching of his daughter, mentioning her by name, posted and reposted on the Internet

is a sufficient privacy interest worthy of protection.

5. The Florida Supreme Court in establishing the standard in Barron v.

Florida Freedom Newspapers, Inc. for issuing such injunctions relied on and

approved the injunction issued in Sentinel Communications Co. v. Smith, finding that

such was proper “because of the express finding of injury to an innocent third party. In

that proceeding, the trial judge determined that a minor child had been adversely

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affected by the litigation and that continued publicity would in all likelihood be ‘highly

detrimental’ to that child.” Id. at 119; Sentinel Communications Co. v. Smith, 493 So.

2d 1048, 1049 (Fla. 5th DCA 1986) 4.

6. Moreover, a restriction on a party’s free speech rights made by a trial court

may be properly made so long as such is based on findings of the need for such

limitation and such limitation is narrowly tailored to meet that need. Delgado v. Miller,

314 So. 3d 515, 518 (Fla. 3d DCA 2020).

7. IRREPARABLE HARM: The Former Wife seeks an injunction to prevent

the Former Husband, who has sought out the direct involvement of “journalist” Mr.

Volpe, from providing and posting on the Internet further information regarding the

parties’ minor children that could cause even more harm than has already been done.

Specifically, the Former Wife seeks to protect the parties’ minor children from the further

intrusion of their privacy rights and from the unsubstantiated and abominable allegations

that the Former Husband has communicated to Mr. Volpe with the intent to broadcast

them on the Internet. The Former Husband is seeking out the attention of “journalists” to

place such intrusions on the minor child directly in the public eye. If an injunction is not

entered, it is clear that, as evidenced by the above, such will permit the immediate and

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The Court in Barron v. Florida Freedom Newspapers, Inc. disapproved of Sentinel
Communications Co. v. Smith only to the extent that it incorrectly found that
newspapers have a greater or different right of access to court proceedings or records
than does the public generally. Sentinel Communications Co. v. Smith, 493 So. 2d
1048, 1049 (Fla. 5th DCA 1986), disapproved of by Barron v. Florida Freedom
Newspapers, Inc., 531 So. 2d 113 (Fla. 1988).

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irreparable harm to the minor children to continue and escalate, given that the stakes

are being raised as this litigation goes on and the Former Husband’s reaction thereto.

8. ADEQUATE REMEDY AT LAW: The Former Wife has no adequate

remedy at law without an injunction based on the Former Husband’s actions. The

Former Wife believes that, based on the Former Husband’s solicitation of Mr. Volpe and

his misguided acts to “expose” this case at all costs, that the Former Husband will

continue to put the parties’ minor children at risk by discussing the very sensitive issues

in this case.

9. LIKELIHOOD OF SUCCESS ON THE MERITS: The Former Wife further

asserts there is a great likelihood of success on the merits as the Former Husband has

clearly demonstrated his willingness to repeat the allegations related to his daughter,

exemplified by the information disseminated by Mr. Volpe on June 23, 2021 and June

24, 2021. It is also the Former Wife’s understanding that one of the video interviewers

that the Former Husband has communicated with posts weekly videos on the subject

every Wednesday such that it is extremely likely that by June 30, 2021, there will at

least be one more video on the subject. On June 29, 2021, Mr. Volpe posted more

information on his website, including video’s of timesharing exchanges and a

supervised visitation report.

Moreover, the Former Wife is even more likely to succeed on the merits given

that it has already been ordered by this Court through the Amended Agreed Order to

Release Eric Satin Jail No: 21024402 From Miami-Dade County Jail With Conditions on

February 22, 2021 that as a condition of the Former Husband’s release, he “shall not

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post on any social media platform any information about this case, any information

related to any party (including the minor children) or any professional involved in this

case.” Unfortunately, this is a condition which the Former Husband has willfully and

repeatedly violated.

The Former Husband was further ordered in the aforementioned Agreed Order

not to communicate with any litigants in other active Miami-Dade County cases

regarding this case or anyone else involved in this case, yet he admits in the June 24,

2021 video with Mr. Volpe that he reached out to more than six (6) different people who

he got in contact with Mr. Volpe.

10. PUBLIC INTEREST: It could not be clearer that the public interest will be

protected by granting this injunction. A five-year-old girl’s reputation and right to privacy

is under attack on the Internet and is subject to further harm in perhaps the most

intimate and harmful way possible should this be permitted to continue.

11. COGENT REASONS: Case law could not be more explicit that the harm

being pled herein constitutes cogent reasons warranting the injunction sought. Namely,

the Florida Supreme Court in establishing the factors that constitute cogent reasons for

granting such injunctions specifically named those to protect children as innocent third

parties in dissolution cases such as this. See Barron v. Florida Freedom Newspaper,

Inc. at 118. Further, another harm which the Florida Supreme Court stated as valid

grounds for granting such an injunction is when allowing the publicity surrounding the

case to continue would be highly detrimental to the parties’ minor child. Id.

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12. BOND: The Former Wife requests that this Honorable Court require a

minimal bond of $100.00. The Father is currently not paying any child support pursuant

to the Final Judgment of Dissolution of Marriage.

13. The Former Wife has incurred attorney’s fees and costs in connection with

the filing of this Motion, and requests that the Court award her attorney’s fees and costs

pursuant to Bitterman v. Bitterman, 714 So. 2d 356 (Fla. 1998) and any other

applicable case or statutory law.

WHEREFORE, the Former Wife files the above styled Motion and respectfully

requests the following narrowly tailored relief:

A. That an injunction be entered restricting the Former Husband from providing

any media outlet, social media platform, or any third party not directly

associated with this case information related to the minor children as it relates

to the details of this case, including, information related to supervised visits,

sexual abuse allegations, names of the children, videos related to the children

or that disclose their residence, information regarding any allegations in this

case related to the children that involve sensitive information, and any other

cogent reason to protect the privacy of the minor children;

B. The Former Husband should be ordered to immediately serve a written

request to Mr. Volpe or any other media outlet to remove any information

related to the minor children, including, but not limited to, any information that

broadcasts their name, their likeness or otherwise discusses or involves

information related to the children.

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C. That the Former Husband immediately provide a list of any and all information

that he has provided to Mr. Volpe or any other media outlet regarding this

case.

D. That the Former Husband be ordered to take down the postings on his social

media page(s) regarding anything related to this case as previously ordered.

E. That the Court grant the Former Wife’s request for attorney’s fees and costs.

Under penalties of perjury, I declare that I have read this document and the facts

stated in it are true.

_________________________

GERI SATIN, Former Wife

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been
served via electronic mail to: CINDI KAMEN, Esquire, Cindi@cindikamenlaw.com;
DIANE M. TRAINOR, Esquire, Dadeland West Executive Office Park, Suite 210, 10689
North Kendall Drive, Miami, Florida 33176, Diane@MTrainorlaw.com,
Ybert@DMTrainorlaw.com; Leslie Ferderigos, Esquire, 10454 Birth Tree Lane,
Windermere, Florida, 34786, leslie@leslieannlaw.com ;this 30th day of June, 2021.

ABRAMOWITZ and ASSOCIATES

3211 Ponce de Leon Blvd,
Suite 202
Coral Gables, Florida 33134
Tel: 305-254-4500
Email:eserviceabramowitz@gmail.com

/s/ Jordan B. Abramowitz

__________________________
Jordan B. Abramowitz, Esquire
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