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ounsel for Plaintiff/Counter-Defendant Jeffrey Epstein CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. Is/ Kara Berard Rockenbach 15 EFTA00808470
ATE TRIALS BECAUSE THE CLAIMS INVOLVE INTERRELATED FACTUAL ISSUES AND, THEREFORE, A RISK OF INCONSISTENT VERDICTS EXISTS. "[A] severance under Florida Rule of Civil Procedure 1.270(b), while residing in the sound discretion of the trial court upon an appropriate showing, should remain the exception." Travelers
ff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. 1st Kara Berard Rockenbach Kara Berard Rockenbach 24 EFTA00793716
Edwards filed his motion to set case for trial, 7 EFTA00793699 the case was not at issue, and thus, the scheduled trial may not proceed based on Florida Rule of Civil Procedure 1440.5 (App. 15). Upon receiving Edwards' Supplement to his Motion for Separate Trials, Epstein's counsel immediately researched the Rule
conda Counsel for Petitioner/Plaintiff Jeffrey Epstein CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. Is! Kara Berard Rockenbach Kara Berard Rockenbach 19 EFTA00793748
time Edwards filed his motion to set case for trial, the case was not at issue, and thus, Epstein's case against Rothstein may not proceed based on Florida Rule of Civil Procedure 1.440. (App. 15). Rule 1.440 provides: (a) When at Issue. An action is at issue after any motions directed to the last pleading served
Entities connected to both Petition and Florida Rule of Civil

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONScott Rothstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATIONJack Scarola
PERSON
Scarlett Johansson
PERSONGoldberger & Weiss
ORGANIZATION
Kenneth Marra
PERSON
United States
LOCATION
Donald Trump
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONMarc S. Nurik
PERSONPalm Beach County Courthouse
LOCATION
Alexander Acosta
PERSONRobert D. Critton
PERSON