Epstein Secrets

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel 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 13, 3 018. B~I

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

erry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 and Philip M. Burlington Nicole J. Segal BURLINGTON & ROCKENBACH, M. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Attorneys for Respo

xists, and the information finds its light of truth in a court. Until then, the documents are under seal and the "no dissemination" ruling by Judge Hafele has been fully complied with by Epstein and his counsel. The Record Truth is that the Extraordinary Documents Remain Under Seal and No Partial Rel

ustralian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Epstein 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 11 EFTA00805468 LINK & ROCKENBACH, PA 1555 Palm Bea

hat's not the issue. You've done your job." (App. D-2, 59:24.) Even though this Court's stay order did not occur for an entire 24 hours after Judge Hafele's oral ruling on March 8, 2018, Epstein and his counsel took into account that the attendance by the trial judge and counsel at the Palm Beach Count

Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for

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

Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley J. Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 MEE Co-Counsel for

, 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

, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, . Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for De

he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca

assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12

cylaw.com [email protected] [email protected] [email protected] Co-Counsel for Defendant/Counter- Plaintiff Bradley J. Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 pmb@FLAppellate

Beach, FL 33401 1 EFTA00798167 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

CENBACH, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 (561) 721-0400 Attorneys for Res ondents By: /s/ Philip M. Burlington PHILIP M. BURLINGTON Florida Bar No. 285862 By: /s/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 /kbt 2 EFTA00798168 SERVICE LI

e, dated November 6, 2017 A21-33 4. Defendant Rothstein's Motion to Set Aside Default, dated A34-36 February17, 2010 Attorneys filing appendix: Philip M. Burlington, Esq. Nichole J. Segal, Esq. BURLINGTON & ROCICENBACH, P.A. 444 West Railroad Avenue, Suite 350 West Palm Beach, FL 33401 1 EFTA00798167 CERT

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

TE OF TYPE SIZE & STYLE Respondents hereby certifies that the type size and style of the Response of Respondents is Times New Roman 14pt. By: /s/ Philip M. Burlington PHILIP M. BURLINGTON Florida Bar No. 285862 By: /s/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 28 EFTA00808546 CERTIFICATE OF

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

Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley J. Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, . Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for De

d: cc: Kara Berard Rockenbach Philip M. Burlington Nichole J. Segal Clerk Palm Beach dl John Scarola Scott J. Link Rachel Jenny Glasser Hon. Donald W. Hafele LONN WEISSBLUM, Clerk Fourth District Court of Appeal Marc S. Nurik Jack Alan Goldberger Bradley J. Edwards EFTA00792286

l apply only to the trial of the underlying matter. Respondents request for expedited consideration is denied. Served: cc: Kara Berard Rockenbach Philip M. Burlington Nichole J. Segal Clerk Palm Beach dl John Scarola Scott J. Link Rachel Jenny Glasser Hon. Donald W. Hafele LONN WEISSBLUM, Clerk Fourth Dist

T (Adds Item No. 22) PLEASE TAKE NOTICE that this case is currently set on the Court's trial docket for August 2 and 3, 2018, before The Honorable Donald W. Hafele, Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida, Courtroom 10D, on the following matters: No. Motion/Request Dat

VICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. ounse Bradley J. Edwards laintiff Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, P.A. 50 o- ounse or en Bradley J. Edwards an ounter-Plaintiff 3 EFTA00793297 Bradley J. Edwards