Epstein Secrets

Epstein here, the plaintiff argued that strict compliance with Rule 1.440 was required. The plaintiff relied upon a previous First District opinion, Bennett v. Continental Chemicals, Inc., 492 So.2d 724 (Fla. 1st DCA 1986), in which the court adopted a bright line rule that strict compliance with Rule 1

Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Attorneys for Res ondents ' Petitioner did not include , or Jane Doe in the caption of the Petition, however, they have been granted leave to appear in the trial court as Intervenor. i EFTA00808515 TABLE OF CONTENTS PAGE TABLE OF CONTENTS ii

because there was no default against Rothstein on the operative complaint. Florida law is clear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added).6 At the earliest opportunity on the next business day, Monday,

ff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. 1st Kara Berard Rockenbach Kara Berard Rockenbach 24 EFTA00793716

se for trial, the "action" is not "at issue" when Edwards made his request. Florida law is clear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d

conda Counsel for Petitioner/Plaintiff Jeffrey Epstein CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. Is! Kara Berard Rockenbach Kara Berard Rockenbach 19 EFTA00793748