Epstein Secrets

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

im which has neither been answered nor defaulted, then the entire action (excluding only crossclaims) is not at issue. See Fla. R. Civ. P. 1.440. 6 Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Ha. 5th DCA 2016) ("Strict compli

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,"

ear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compl

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

ear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compl