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Edwards filed a "Supplement" to his Motion for Separate Trials (App. 15). In his Supplement, Edwards advised 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, 7 EFTA00793699
not at issue. See Fla. R. Civ. P. 1.440. 6 Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Ha. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker
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
727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker
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,
727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker
Entities connected to both the Second Amended Complaint and Schoof

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJack Scarola
PERSONScott Rothstein
PERSON
Gawker
ORGANIZATION
Donald Trump
PERSON
George W. Bush
PERSON
Bennett
PERSONGawker Media
ORGANIZATIONBollea
PERSONDonald W. Hafele
PERSONFlorida Rule of Civil
ORGANIZATIONFOURTH DISTRICT
LOCATION
Naomi Campbell
PERSONMark Nurik
PERSONNichole J. Segal
PERSONBroward Marine, Inc.
ORGANIZATIONMarc S. Nurik
PERSONMotion for Default Against
ORGANIZATION