Epstein Secrets

a true and correct copy of this Reply Brief was served on this day of December, 2018 by electronic mail to: Joe Titone, Esq., 621 S.E. 5th Street, Pompano Beach, FL 33060 ([email protected]). LINK & ROCKENBACH, PA Counsel for Appellant 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 3340

Appellees/Plaintiffs. REPLY BRIEF OF APPELLANT On Appeal from a Non-Final Order of the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) LINK & ROCKENBACH, PA Counsel for Appellant 1555 Palm Beach Lakes Blvd.,

ket. From paperboy, he went on to sell vacuum cleaners and eventually made enough to buy a McDonald's restaurant. In the mid-'80s, Falcone moved to Pompano Beach and by 1987 had bought the franchises to 38 South Florida Wendy's restaurants. Soon he and his brothers, Arthur and Robert, would own more than 100

lawsuits in the past year allege financial flakiness and fraud on the part of the brothers. In May 2009 Ocean Bank sued Edward and Arthur Falcone in Miami-Dade County court for failing to pay installments of a $48 million loan. Three months later, PNC Bank also sued them, claiming they lied about $900,000 in asse

the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Joe Titone Attorney for Appellant Florida Bar No. 203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: (954)729-6490 [email protected] 1 EFTA00792289 TABLE OF CONTENTS TABLE OF AUTHORITIES 4 STATEMENT OF THE CASE AND

tiffs. I ANSWER BRIEF OF APPELLEES/PLAINTIFFS On Appeal from a Non-Final Order of the Circuit Court of the Eleventh Judicial Circuit in and for Miami-Dade County, Florida Joe Titone Attorney for Appellant Florida Bar No. 203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: (954)729-6490 joetitone708@

oom DCC 416, Miami, Florida 33130. PLEASE GOVERN YOURSELF ACCORDINGLY. Is/ Joe Titone Joe Titone Attorney FL BAR #: 203882 621 S.E. 5th Street Pompano Beach, Florida 33060 (954) 729-6490 (954) 941-2232 (FAX) [email protected] 1 EFTA00620175 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a cop

n to Quash Attempted Service, before the Honorable Rodney Smith on June 22, 2016 at 9:00 ■. or as soon thereafter as the matter may be heard, at the Miami-Dade County Courthouse, 73 West Flagler Street, Room DCC 416, Miami, Florida 33130. PLEASE GOVERN YOURSELF ACCORDINGLY. Is/ Joe Titone Joe Titone Attorney

Math Vlass41§ I Gent/emon'S"Club tri , Private xotic Suites Fully Equipped Dungeon .,4100W , VALIIN, , FRI 8. SAT: 10AM-4AM 954.781:.0290 Hwy. Pompano Beach rr he East Side.1,eitete Rea' Pekin 3 Ard Entralce 5,Iwoys Hiring Apply in Person Beatitul Exotic Lades )PEN 7 DAYS TOAM-DAM ENJOY THE SUMMER HE

for all adult entertainment establishments in the Eleventh Circuit if not county wide. Also, the case of the three adult book stores who sued Miami-Dade County to allow doors on adult viewing booths, is still going on. Interrogatories • COSTUMES • soar JEWELS a JEWELRY • falIPONARY TATTOOS • mos • wimp

01 Jeffrey Epstein's Proposal for Settlement to Ma Model & Talent Miami, LLC Page 3 Joe Titone, Esq., Counsel for Plaintiffs, 621 S.E. 5th Street, Pompano Beach, FL 33061, E-Mail by E-Mail, this day of September, 2015. W. CHESTER BREWER, JR., P.A. Attorneys for Jeffrey Epstein Phone Fax E-Mail: By: W

TALENT MIAMI. LLC vs. JEFFREY EPSTEIN. TYLER McDONALD: and TYLER McDONALD d/b/a YLORG, 1 I th District Court Case No. 2014- 21348-CA-01, in and for Miami-Dade County, Florida ("the Action"). It is understood and agreed that this settlement is the compromise of a doubtful and disputed claim, and that the payment