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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,
harm); and (2) a departure from the essential requirements of the law." Nader v. Fla. Dep't of Highway Safety & 7 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou
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
Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015). The petitioner need demonstrate only that (1) the 3 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou
set 5 EFTA00793771 the cause for trial, the "action" was not "at issue." 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
uit court denied the motion. (App. 18). The court recognized the case was not at issue at the time the motion to 5 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit cou
Entities connected to both Bennett and Motion for Default Against

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Chris Tucker
PERSON
Naomi Campbell
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSONFOURTH DISTRICT
LOCATION
Melbourne
LOCATIONDonald W. Hafele
PERSONthe Second Amended Complaint
ORGANIZATIONBollea
PERSON
Gawker
ORGANIZATIONGawker Media
ORGANIZATIONFlorida Rule of Civil
ORGANIZATIONParsons
ORGANIZATIONAnheuser-Busch, Inc.
ORGANIZATIONReilly
PERSON