Epstein Secrets

, 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

Epstein agreed and objected before trial occurred. Edwards' attempt to pigeon-hole this case to fit within the purview of Labor Ready Se. Inc. v. Australian Warehouses Condo. =, 962 So. 2d 1053 (Fla. 4th DCA 2007), and HSBC Bank USA,.. v. Serban, 148 So. 3d 1287 (Fla. 1st DCA 2014), is unavailing. In fact, the instant

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,"

ke in this case—an amended pleading is filed subsequent to an otherwise compliant order setting_trial under Rule 1.440. See Labor Ready Se. Inc. v. Australian Warehouses Condo. Ass'n, 962 So. 2d 1053 (Fla. 4th DCA 2007). Labor Ready was another final appeal, not a mandamus proceeding. The appellant in that case argued tha

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

, 18, 19, 20 148 So.3d 1287 (Fla. 1st DCA 2014) Jane Doe No. 1, et al. v. United States, 4 749 F.3d 999 (11th Cir. 2014) Labor Ready Se. Inc. v. Australian 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 94

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 are "at issue" and reported decisions from this Court and other appellate courts on the mandatory nature of the rule. See Labor Ready Se. Inc. v. Australian Warehouses Condo. Ass 'n, 962 So. 2d 1053 (Fla. 4th DCA 2007)(brought on final appeal, not mandamus, and therefore Rule 1.440 was "waived [by] the aggrieved party w