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,"

raises no objection to the noncompliance." [e.a.] Id. at 1055 (quoting Parrish, 505 So. 2d at 648). The case at bar is clearly distinguishable from Labor Ready. First, Epstein did not waive the error by appearing at trial without raising an objection. See id. Again, Epstein adamantly voiced his objection b

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

this Court's Labor Ready decision as the controlling precedent governing his authority to deny Epstein's motion to remove the case from the docket. Labor Ready, though well-decided, is both distinguishable and inapplicable to this case. First of all, Labor Ready was a final appeal, not a mandamus proceedin

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

e final hearing without objection. No one argued they were not ready for trial, but simply argued a technical violation of rule 1.440. On appeal in Labor Ready, the defendants argued that the Rule 1.440 violation entitled them to a new hearing. This Court rejected the argument, noting that the defendants'