Epstein Secrets

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

21, 2010, a Clerk's Default was entered against Rothstein as to all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

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

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

21, 2010, a Clerk's Default was entered against Rothstein as to all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

BECAUSE THE CIRCUIT COURT MUST REMOVE THE CASE FROM THE TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440. In violation of Florida Rule of Civil Procedure 1.440, this case was not "at issue" when Edwards filed his Motion to Set Case for Trial. Therefore, the circuit court's ensuing Order set

d from this case on August 9, 2010. (App. 5). 5 EFTA00793697 all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

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