Epstein Secrets

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

ly described it, "The Pretrial Stipulation is a powerful blueprint that fully enables a well-run and fair trial." Palm Beach Polo Holdings, Inc. v. Broward Marine, Inc., 174 So. 3d 1037, 1039 (Fla. 4th DCA 2015). It is "the trump card upon which all parties to any litigation can virtually always rely." Id. at 1038.

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

sues on which a case is to be tried are binding upon the parties and the court, and should be strictly enforced." Palm Beach Polo Holdings, Inc. v. Broward Marine, Inc., 174 So. 3d 1037, 1039 (Fla. 15 EFTA00793744 4th DCA 2015) (emphasis added; citation and internal quotation marks omitted). Judge Hafele specifi

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,

sues on which a case is to be tried are binding upon the parties and the court, and should be strictly enforced." Palm Beach Polo Holdings, Inc. v. Broward Marine, Inc., 174 So. 3d 1037, 1039 (Fla. 4th DCA 2015) (emphasis added; citation and internal quotation marks omitted). Judge Hafele specifically cited this ca