Epstein Secrets

/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 /kbt 29 EFTA00808547 SERVICE LIST Epstein v. Rothstein/Edwards Case No. 4D18-0762 Scott J. Link, Esq. Kara Berard Rockenbach, Esq. Rachel J. Glasser, Esq. LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd. Ste. 301 h, Florida 33401 Attorney

15 EFTA00808533 C. Epstein Waived the Right to Rely on Rule 1.440 Epstein has waived reliance on Rule 1.440. As discussed above, Epstein filed the Second Amended Complaint on August 22, 2011. Rothstein never answered the complaint. Pursuant to Rule 1.500(a), Florida Rules of Civil Procedure, it was incumbent upon Epst

sponse in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate Set Forth in Rule 1.440 COUNSEL LIST Scott J. Link, Esq. Link & Rockenbach, 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach. FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Jack A. G

ded Complaint, which was filed on August 21, 2011. 4. Edwards, however, is not a party to that case as Epstein voluntarily dismissed Edwards from the Second Amended Complaint on August 16, 2012.' That point alone nullifies Epstein's entire argument that Edwards' Motion to Set Case for Trial was not ripe. Rule 1.440(b), o

iew of a Non-Final Order of the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida Kara Berard Rockenbach, Esq. Scott J. Link, Esq. Rachel J. Glasser, Esq. Link & Rockenbach, PA Appellate Counsel for Petitioner EFTA00793693 INTRODUCTION In this Petition for a Writ of

Edwards filed a "Supplement" to his Motion for Separate Trials (App. 15). In his Supplement, Edwards advised for the first time that no default on the Second Amended Complaint had been entered in Epstein's case against Rothstein. In other words, at the time Edwards filed his motion to set case for trial, 7 EFTA00793699

iew of a Non-Final Order of the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County, Florida Kara Berard Rockenbach, Esq. Scott J. Link, Esq. Rachel J. Glasser, Esq. Link & Rockenbach, PA A ellate Counsel for Petitioner EFTA00793730 INTRODUCTION In this Emergency Petition for a

m., in a "Supplement" to his Motion for Separate Trials filed just the day before (App. 14), Edwards asserted for the first time that no default on the Second Amended Complaint had been entered in Epstein's case against Rothstein. In other words, at the time Edwards filed his motion to set case for trial, the case was not