Epstein Secrets

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,"

t 421. 7 EFTA00793736 respondent is duty-bound to act under the law, and (2) the respondent has failed or refused to do so. Id. (citing Pleus v. Crist, 14 So. 3d 941 (Fla. 2009)). "A third and final element is that the petitioner must have no adequate legal remedy for the respondent's failure to c

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

strate only that (1) the respondent is duty-bound to act under the law, and (2) the respondent has failed or refused to do so. Id. (citing Pleus v. Crist, 14 So. 3d 941 (Fla. 2009)). "A third and final element is that the petitioner must have no adequate legal remedy for the respondent's failure to c

Bar No. 41232 28 EFTA00808546 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack

ralian Warehouses Condo. ffi, 14, 16, 17 962 So.2d 1053 (Fla. 4th DCA 2007) Parrish v. Dougherty, 14 505 So.2d 646 (Fla. 1st DCA 1987) Pleus v. Crist, 22 14 So.3d 941 (Fla.2009) Poole v. City of Port Orange, 1 33 So.3d 739 (Fla. 5th DCA 2010) iii EFTA00808517 Sica v. Singletarv, 714 So.2d