Epstein Secrets

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

ATE TRIALS BECAUSE THE CLAIMS INVOLVE INTERRELATED FACTUAL ISSUES AND, THEREFORE, A RISK OF INCONSISTENT VERDICTS EXISTS. "[A] severance under Florida Rule of Civil Procedure 1.270(b), while residing in the sound discretion of the trial court upon an appropriate showing, should remain the exception." Travelers

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

Edwards filed his motion to set case for trial, 7 EFTA00793699 the case was not at issue, and thus, the scheduled trial may not proceed based on Florida Rule of Civil Procedure 1440.5 (App. 15). Upon receiving Edwards' Supplement to his Motion for Separate Trials, Epstein's counsel immediately researched the Rule

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

ify them on his Exhibit List. Edwards has provided not a single reason why this Court should expedite its careful review and enforce the mandate of Florida Rule of Civil Procedure 1.440 (Petition for Writ of Mandamus) and determine if the severance of the interrelated and dependent actions should continue to one jur

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,"

time Edwards filed his motion to set case for trial, the case was not at issue, and thus, Epstein's case against Rothstein may not proceed based on Florida Rule of Civil Procedure 1.440. (App. 15). Rule 1.440 provides: (a) When at Issue. An action is at issue after any motions directed to the last pleading served

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

BECAUSE THE CIRCUIT COURT MUST REMOVE THE CASE FROM THE TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440. In violation of Florida Rule of Civil Procedure 1.440, this case was not "at issue" when Edwards filed his Motion to Set Case for Trial. Therefore, the circuit court's ensuing Order set

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

s were consolidated for panel purposes on March 16, 2018. EFTA00808506 The consolidated appeals concern a violation of the mandatory language in Florida Rule of Civil Procedure 1.440 that requires a court to set an action for trial only when all claims and counterclaims are "at issue" and reported decisions from

ed envelopes so that this court may set other trials in its place. DONE AND ORDERED at Palm Beach County, Florida, thimittedit10 DATE MAY 1 2 2010 Donald W. Hafele, autifilanALD W RAFE t f. Copies furnished to: Bradley J. Edwards, Esq., Attorney for Plaintiff 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33

s do not appear for, participate, or complete mediation, this Court may impose sanctions. If a party opposes mediation, that party may proceed under Florida Rule of Civil Procedure 1.700(b). O. Noncompliance, Noncompliance with any portion of this order may result in the striking of the case, witnesses, or exhibits,

davits of T. Campbell and T. Chinaris; work on schedule of motions to be heard; communications with D. Indyke; prepare letter and package to Judge Hafele re additional hearing submissions; prepare letter to J. Scarola re delivery of disc; carefully review redacted appendix to see if we missed redact

Include "at issue" argument 03/03/18 KBR Work on preparations for trial; work on Motion to 7.30 Remove Case from Trial Docket in compliance with Florida Rule of Civil Procedure 1.440; work on Response to B. Edwards' Motion to Severe; conduct legal research on appellate vehicle should the Court grant B. Edwards'

0-minute Special Set Hearing on Defendant Epstein's Motion for Sanctions against Spencer Kuvin, Esq. and Alternative Motion to Identify Dear Judge Hafele: With reference to the above-mentioned 30-minute special set hearing on January 26, 2010, enclosed please find Defendant, Epstein's Supplement to H

AMAGES Plaintiff, B.B., by and through undersigned counsel, and files this Motion for Leave to Amend Complaint to Seek Punitive Damages pursuant to Florida Rule of Civil Procedure 1.190(f) and F.S. § 768.72 and as grounds therefore, states as follows: R.I.C.O. 1. This is an action currently includes a cause of act