Epstein Secrets

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

15 EFTA00808533 C. Epstein Waived the Right to Rely on Rule 1.440 Epstein has waived reliance on Rule 1.440. As discussed above, Epstein filed the Second Amended Complaint on August 22, 2011. Rothstein never answered the complaint. Pursuant to Rule 1.500(a), Florida Rules of Civil Procedure, it was incumbent upon Epst

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

Edwards filed a "Supplement" to his Motion for Separate Trials (App. 15). In his Supplement, Edwards advised for the first time that no default on the Second Amended Complaint had been entered in Epstein's case against Rothstein. In other words, at the time Edwards filed his motion to set case for trial, 7 EFTA00793699

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

longer applied. Mr. Edwards pointed out to this Court and to Mr. Epstein -- he is absolutely correct -- that Mr. Epstein's operative complaint is the Second Amended Complaint to which there is no default. What rule 2.440 tolls this Court to do is to look at the time that Mr. Edwards moved -- it's maybe a notice to set

tempting to resolve discovery issues in this and EFTA00222521 Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 2 of 4 Jane Doe No. 2 v. Epstein Page 2 other cases against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who works extensively on this case

522 Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 3 of 4 Jane Doe No. 2 v. Epstein Page 3 Defendant to respond to the Second Amended Complaint. Robert D. •ritton, Jr. Attorney f r Defendant Epstein Certificate of Se ce I HEREBY CERTIFY that a true copy of the foregoing was electronicall