Epstein Secrets

vidually, Respondents/Defendants.1 REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI On Review 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 C

ded). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was "factually . . . some overlap," and that he was "not suggesting [otherwise]." (App. 19, p. 222.) And no less than six times

Jay Howell & Associates 644 Cesery Blvd., #250 Jacksonville, FL 32211 Co-Counsel for Intervenors E.W., and Jane Doe 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 14 EFTA00808469 LINK & ROCKENBACH, PA 1555 Palm Bea

bifurcating claims which involve interrelated factual issues because severance risks inconsistent outcomes.") (emphasis added). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was

ial facts necessary ~o establish the ••• cl.aims .·asseri:eq. because rieither Defendant Aron berg, nor The Office. of the State Attorn~y for the . Fifteenth Judicial Circuit is. in custody or control of the .2006 grand jury !materials sought therein: Simply put, the deciaratory n:lief sought by the Plaintiff, seeks recor

review of summons and complaint. $425.00 1.5 $637.50: 11/26/2019 ow Review Reviewecj motion for pro hac vice and Judge $425.00 0.2 $85.00 Hafele' order granting 11i26/2019 ow Teleconference Teleconference w/ Clf_ent, re: response to lawsuit $425.00 0.5 $212.50 11/26/2019 ow Draft Dr

tal 11/26/2019 bw Review Initial review of summons and complaint. $425.00 1.5 $637.50 11/26/2019 DW Review Reviewed motion for pro hac vice and Judge Hafele' order granting $425.00 0.2 $85.00 11/26/2019 DW Teleconference Teleconference w/ Client, re: response to lawsuit $425.00 0.5 $212.50 11/26/2019 DW D

DLEY J. EDWARDS, individually, Respondents/Defendants. PETITION FOR WRIT OF CERTIORARI On Review 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 C

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

Respondents/Defendants. REPLY TO RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review 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 C

, over more than six years, to seek a default against Rothstein[.]" (Resp. at p. 1) [emphasis added]. However, at the March 8, 2018, hearing, Judge Hafele held Edwards equally responsible for the current Rule 1.440 issue because Edwards was the party who 2 EFTA00808473 noticed the case for trial an

in 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 Jeffrey Eps

EDWARDS, individually, Respondents/Defendants. EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review 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 Co

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,"

portedly improperly representing his clients who were Epstein's sex abuse victims. Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and LM., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 4. On April 17, 2010, Epstein ser

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

AWYER et z-N--,.\ .. 2.) \ '- ? BURMAN, CRITTON, LUTTIER & COLEMAN LLP A LIMITED LIABR,TT'Y PARTNERSHIP BY HAND DELIVERY Judge Donald Hafele Fifteenth Judicial Circuit April 13, 2009 ADELQUI J. BENAYENTE PARALEGAL/ INVESTIGATOR BARBARA M. McKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK O

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

vtAN, CRITTON LUTTIER&COLEMAN.LLY YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP December 9, 2009 BY HAND DELIVERY Judge Donald Hafele Fifteenth Judicial Circuit Palm Beach Conn Courthouse Re: acember 14, 2009 UMC Hearing v. Jeffrey Epstein CASE NO.: 502008CA037319)OOOCMB AM ADELQI,PI J. BENAVENTE PAPAL

OBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing be

NICK DAVID A. YAREMA Inomon WARD CERTIFIED CIVIL TlUAL ueorna 2ADMITT1D TO PRACTICE IN FLORIDA AND COLOMDO BY HAND DELIVERY Judge Donald Hafele Fifteenth Judicial Circuit Attn: Denise Vanvooren BURMAN, CRITTON LUTTIERSLCOLEMAN.LLP YOUR TRUSTED ADVOCATES A LIMITED LIABILITY PARTNERSHIP June 23, 2010 Re: B.B. v.

SSICA CADWELL BOBBIE M. MCKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA FL BUDKYK Of COUNSEL EDWARD M. RICCI or COUNSEL Dear Judge Hafele: Enclosed please find proposed Stipulation and Order of Dismissal with Prejudice in the above-styled matter. Plaintiff's counsel has reviewed and

C..-.:ca...., -4-•-1/4) , .... . - BURMAN, CRITTON, LUTTIER & COLEMAN LLP A LIMITED LIABILITY PARTNERSHIP BY HAND DELIVERY Judge Donald Hafele Fifteenth Judicial Circuit April 13, 2009 ADELQUI J. BENAYENTE PARALEGAL/ INVESTIGATOR BARBARA M. WHENNA ASHLIE STOKEN-BARINO BETTY STOKES PARALEGALS RITA H. BUDNYK OP

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to