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OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Bea
emicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A. 1 204 So.3d 476 (Fla. 4th DCA 2016) Gawker Media, LLC v. Bollea 20, 21, 22 170 So.3d 125 (Fla. 2d DCA 2015) Grossman v. Fla. Power & Light Co., 14 570 So.2d 992 (Fla. 2d DCA 1990) Haft v. Adams, 1 238 So.2
nd that she had to see a therapist in Miami at her attorney's request and fake cry, pretend like she was damaged and pretend she had been molested; Jane Doe No. 7 was laughing about it. Id. at 264; h. Jane Doe No. 7 never complained that Epstein acted inappropriately or that she suffered any emotional
finding of insufficient evidence [ J constitute[d] a departure from the essential requirements of the law." Id. See also Cypress Aviation, Inc. v. Bollea, 826 So. 2d 1091, 1092 (Fla. 2d DCA 2002) (holding that "Florida law is clear" that a plaintiff must provide the court with an evidentiary basis bef
2 At the March 8, 2018 hearing, University of Utah Law Professor, Paul G. Cassell, Esq., appeared pro hac vice below for non-parties L.M., E.W. and Jane Doe, on a limited confidentiality issue not before this Court. On behalf of non-parties, L.M., E.W. and Jane Doe, Mr. Cassell filed an Unopposed Emerge
69, 170 (Ha. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015) ("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440, including its mandat
11 would ask the Court to address first. By KAREN TERRY, ESQUIRE 12 I would like to introduce to Your Honor II 12 For Non-Parties L.M.. E.M. 4 Jane Doe 13 University of Utah Law Professor Paul 13 HATCH. JAMES 4 DODGE, P.C. 14 Cassell, former Federal Judge Paul Cassell, 15 who will present tha
or versus Bolloa District, as far as the Court is concerned, is the Labor Ready Southeast, Inc. versus Australian Warehouses Condominium 4 case. Bollea, if I recall correctly, is A Association case. But not so much for the S Hulk Hogan from wrestling. Court's position that it's taking as it 6
Entities connected to both Jane Doe and Bollea

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
George W. Bush
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Donald Trump
PERSONGoldberger & Weiss
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION
Naomi Campbell
PERSON
Searcy
PERSON
Chris Tucker
PERSONMarc S. Nurik
PERSON
Scott J. Link
PERSONNichole J. Segal
PERSONPetition
ORGANIZATIONPalm Beach County Courthouse
LOCATIONBurlington & Rockenbach
ORGANIZATIONDonald W. Hafele
PERSON