Epstein Secrets

ties Fowler White and Farmer Jaffe consent to the jurisdiction of this Court solely for purposes of participating in the mediation. 2. Pursuant to Florida Rule of Civil Procedure 1.720, Edwards, Epstein, the Intervenors and representatives from Fowler White and Farmer Jaffe who have the full authority to settle wit

m Beach County, Florida this day of August, 2018. THE HONORABLE DONALD W. HAFELE CIRCUIT COURT JUDGE SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-

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

ICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-

s were consolidated for panel purposes on March 16, 2018. EFTA00808506 The consolidated appeals concern a violation of the mandatory language in Florida Rule of Civil Procedure 1.440 that requires a court to set an action for trial only when all claims and counterclaims are "at issue" and reported decisions from

that a true and correct copy of this request was furnished via email this 19th day of March, 2018, to the following: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc

imary: Primary: Secondary: Secondary: Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00808712 SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Pl

ify them on his Exhibit List. Edwards has provided not a single reason why this Court should expedite its careful review and enforce the mandate of Florida Rule of Civil Procedure 1.440 (Petition for Writ of Mandamus) and determine if the severance of the interrelated and dependent actions should continue to one jur

I HEREBY CERTIFY that a true and correct copy of this request was furnished via email this 14th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] jsx@searcylaw

ivilege log that this Court's predecessor, The Honorable David Crow, found to be insufficient on its face and not-compliant with the requirements of Florida Rule of Civil Procedure 1.280(b)(5)7 and TIG Ins. Corp. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001). Edwards has claimed that none of the documents on the dis

(FBN Primary Primary Second Second Counsel for Counter-Defendant Jeffrey Epstein 20 EFTA00794296 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searc Denn Scarola, Barnhart & Shipley, P.A. yard Co-Counsel for Defendant/Counter-Plaintiff Bradl- J. Edwards Philip M. Burlington Nichol

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc

2991) Kara Berard Rockenbach (FBN 44903 Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00794306 SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] jsx@searcylaw.

AND ADJU follows: 1. Non-party Fannyr Jaffe consents to the jurisdiction of this Court solely for purposes of participating medi&ion. 2. t to Florida Rule of Civil Procedure 1.720, Edwards, Epstein and a repr m Farmer Jaffe who has the full authority to settle without further consultation shall app at the me

- E-AND ORDERED in West Palm Beach, Palm Beach C 44 of August 2018. THE I4 :4 DOT CIRCUIT COURT JUDO SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley . 2139 Palm Beach Lakes Boulevard West Palm Beach FL 33409 • Co-Counsel for Defend miler-Plain