Epstein Secrets

he terms of rule 1.440, including its mandated fifty-day hiatus between the service of the last pleading and the trial date."); Genuine Pans Co. v. Parsons, 917 So. 2d 419 (Fla. 4th DCA 2006) (granting mandamus to enforce Rule 1.440(c), which prohibits the setting of a trial less than thirty days after

anxiety" and "emotional distress" he suffered as a result of Epstein's filing and continuation of this lawsuit. At the March 8, 2018 hearing, Judge Hafele himself recognized no less than six times that Edwards' counterclaim for malicious prosecution against Epstein had its 4 EFTA00793696 genesis in

se or e en ant Scott Rothstein Plaintiff Bradley J. Edwards Jack A. Goldberger WA HAND DELIVERY Atterbu , Goldber er & Weiss, P.A. The Honorable Donald W. Hafele uite 1400 Palm Beach County Courthouse 1 205 N. Dixie Highway, Room 10.1216 o- outzse or amt minter- West Palm Beach, FL 33401 Defendant Jeffr

the setting of a trial under rule 1.440." Campbell v. Wells Fargo Bank, N.A., 204 So. 3d 476, 479 (Fla. 4th DCA 2016) (citing Genuine Parts Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006) and Gawker Media, LLC v. Bollea, 170 So. 3d 125, 130 (Ha. 2d DCA 2015)). I In compliance with this Court's

Atterbury, Goldberger & Weiss, P.A. Suite 1400 01 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein VIA U.S. MAIL ONLY The Honorable Donald W. Hafele 18 EFTA00793747 111111111 By: /s/ Kara Berard Rockenbach Scott J. Link (FRIse Kara Berard Rockenbach (FBN Rachel J. Glasser (FBN Primary: P

d Marine, Inc., 174 So. 3d 1037, 1039 (Fla. 15 EFTA00793744 4th DCA 2015) (emphasis added; citation and internal quotation marks omitted). Judge Hafele specifically cited this case and its holding at the March 8, 2018 hearing, but failed to explain how he could get around it. Again, "this matter,"

e terms of rule 1.440, including its mandated fifty-day hiatus between the service of the last pleading and the trial date."); Genuine Parts Co. v. Parsons, 917 So. 2d 419 (Fla. 4th DCA 2006) (granting mandamus to enforce Rule 1.440(c), which prohibits the setting of a trial less than thirty days after

l follow, addressing the severance order, and may be consolidated with the mandamus petition.' At the March 8, 2018 hearing, Epstein advised Judge Hafele of his intent to file the extraordinary writ petitions in this Court, and made an ore tenus motion for stay of the trial court proceedings pending

Atterbur , Goldber er & Weiss, P.A. Suite 1400 01 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein VIA U.S. MAIL ONLY The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 19 EFTA00793785 LINK & R KENBA H PA By: /s/ Kara B

efore Rule 1.440 was "waived [by] the aggrieved party who appear[ed] at trial and raise[d] no objection to the noncompliance"); Genuine Pans Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006)(issuing a writ of mandamus to enforce strict toning of Rule 1.440(c)); Gawker Media, LLC v. Bollea, 170 So

Jack A. Goldberger Atterbury, Goldberger & Weiss, . 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 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 Co-Counsel for Plaintiff/Counter- Defendant Jed E , st