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

Palm Beach, Palm 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 Def

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

TIFICATE OF SERVICE 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 Defe

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

I HEREBY CERTIFY 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 Defe

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

ICATE OF SERVICE 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]

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

CATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Burlin ton & Rocke

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

rard Rockenbach (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. Bur

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

s Court. DON 4-- 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 Defe