Epstein Secrets

Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I JA LL Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): 644 Cesery Blvd. #250 Jacksonville, FL 32211 And By: /s! Paul G. Cassell PAUL G. CASSELL S.J. Qui

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel hereby certify that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

& Weiss, 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Epstein Jay Howell Jay Howell & Associates 644 Cesery Blvd., #250 Jacksonville, FL 32211 Co-Counsel for Intervenors E.W., and Jane Doe VIA U.S. MAIL The Honorable Donald W. Hafele Palm

ded). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was "factually . . . some overlap," and that he was "not suggesting [otherwise]." (App. 19, p. 222.) And no less than six times

Jay Howell & Associates 644 Cesery Blvd., #250 Jacksonville, FL 32211 Co-Counsel for Intervenors E.W., and Jane Doe VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 14 EFTA00808469 LINK & ROCKENBACH, PA 1555 Palm Bea

bifurcating claims which involve interrelated factual issues because severance risks inconsistent outcomes.") (emphasis added). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was

nhart & Shipley PA and Phil Burlington and Nichole J. Segal of Burlington & Rockenbach PA. L.M., E.W. and Jane Doc arc represented by Jay Howell of Jay Howell & Associates and Paul G. Cassell of Hatch James & Dodge PC. EFTA00793764 The case is In Re: Rothstein Rosenfeldt Adler PA, case number 09-34791, in the U.S. B

stein never even knew Fowler White had the disc until we found it." Counsel for three victims — identified as L.M., E.W. and Jane Doe — asked Judge Hafele to order Fowler White to explain its handling of the confidential documents, but he said he lacked the authority to do so since the firm had withdr

d the materials from Fowler White's files. According to the motion, during a March 8 hearing on the privileged communications, State Circuit Judge Donald W. Hafele said, "The critical question, though, is why did Fowler White have these documents, why were they continued to be held, and was it in violation eith

Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 [email protected] Jay Howell Jay Howell & Associates 644 Cesery Blvd., #250 Jacksonville, FL 32211 [email protected] [email protected] Co-Counsel for Intervenors E.W., L.M. and Jane Doe Co-Couns

he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca

assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12

enbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Jay Howell, Esq. Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell, Esq.

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE N

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

Paul Cassell Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein. Jay Howell Jay Howell & Associates L.M., E.W. Limited Intervenor Co-Counsel for and Jane Doe 4 EFTA00793298 This notice is provided pursuant to Administrative Order No. 2.207-1/

T (Adds Item No. 22) PLEASE TAKE NOTICE that this case is currently set on the Court's trial docket for August 2 and 3, 2018, before The Honorable Donald W. Hafele, Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida, Courtroom 10D, on the following matters: No. Motion/Request Dat

ircuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL, ESQ., Jay Howell & Associates, PA.. and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger EFTA00614418 IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COU

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to