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& Weiss, 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es Esquire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beac FL 33401 Phone: Attorneys for Bradley J. Edwards Bra . J. Edwards, Esquire 425 N Andrews Aven
ded Complaint, which was filed on August 21, 2011. 4. Edwards, however, is not a party to that case as Epstein voluntarily dismissed Edwards from the Second Amended Complaint on August 16, 2012.' That point alone nullifies Epstein's entire argument that Edwards' Motion to Set Case for Trial was not ripe. Rule 1.440(b), o
his Petition was furnished via email this 8'h day of March, 2018: Jack Scarola Sears , Denn , Scarola, Barnhart & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. and i 350 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards B
m., in a "Supplement" to his Motion for Separate Trials filed just the day before (App. 14), Edwards asserted 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, the case was not
ia email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, P.A. 350 1 o- ounse or ee ant Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Edwards Pottin er LLC o- ounse or ee nt ounter-Plainti
recognized the case was not at issue at the time the motion to 5 Epstein simultaneously filed his Motion for Default Against Defendant Rothstein on the Second Amended Complaint. (App. 17). Pursuant to Rule 1.440, the "action" will be at issue 20 days after the circuit court grants Epstein's motion for default. Thereafter,
Entities connected to both Burlington & Rockenbach and the Second Amended Complaint

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJack Scarola
PERSONScott Rothstein
PERSONPalm Beach Lakes Boulevard
LOCATION
Scott J. Link
PERSONMarc S. Nurik
PERSONNichole J. Segal
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
George W. Bush
PERSONJane Doe
PERSONKara Berard Rockenbach
PERSON
Donald Trump
PERSON
Paul Cassell
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONFlorida Rule of Civil
ORGANIZATIONDonald W. Hafele
PERSONFOURTH DISTRICT
LOCATIONRachel J. Glasser
PERSON