Epstein Secrets

RD DISTRICT DCA CASE NO.: 3D18-1997 L.T. CASE NO.: 2014-021348 CA 01 RECEIVED, 11/5/2018 4:55 PM, Mary Cay Blanks, Third District Court of Appeal JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRUNEL, individually, and MC2 MODEL & TALENT MIAMI, LLC, Appellees/Plaintiffs. I ANSWER BRIEF OF APPELLEE

roduction 8 I. The process server's affidavit does not definitively rule out the possibility that two prior attempts were made at service at Epstein's place of business II. The process servers' affidavit does not definitively reflect that the person served with process at Defendant's place o

s App. A). After an unsuccessful attempt to serve Defendant Epstein (Epstein) at his New York residential address, (

Mary Cay Blanks, Third District Court of Appeal JEFFREY EPSTEIN, Appellant/Defendant, VS. JEAN-LUC BRU

203882 62 1SE 5th Street Pompano Beach, FL 33060 Phone: EFTA00792300 CERTIFICATE OF COMPLIANCE I HEREBY CERTIFY that this brief complies with Florida Rule of Appellate Procedure 9.210(a) (2), requiring fourteen-point Times New Roman Font. /s/ Joe Titone Joe Titone Attorney for Appellant Florida Bar No. 203882

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. PETITIONER'S RESPONSE IN

efendants. PETITIONER'S RESPONSE IN OPPOSITION TO RESPONDENT BRADLEY J. EDWARDS' MOTION FOR PARTIAL RELIEF FROM STAY Petitioner, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Appellate Procedure 9.300, responds in opposition to the Motion for Partial Relief from Stay filed by Respondent, Br

: 4D18-0762 LT Case No: 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

d that they are helpful to the position taken by Mr. Epstein." (App. D-2, 51:23-52:5). Upon remand, the trial

S RESPONSE IN OPPOSITION TO RESPONDENT BRADLEY J. EDWARDS' MOTION FOR PARTIAL RELIEF FROM STAY Petitioner, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Appellate Procedure 9.300, responds in opposition to the Motion for Partial Relief from Stay filed by Respondent, Bradley J. Edwards ("Edwards")', on March 1

that they are helpful to the position taken by Mr. Epstein." (App. D-2, 52:2-5.) Judicial light needs to be

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3CXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. MOTION TO STRIKE UNAUTHO

2.510(b)(4). EFTA00805458 order, was solely limited to "seal exhibits." The sealing of allegedly "confidential" exhibits was accomplished through Epstein's repeated initiative and cooperation: (1) Epstein's notice of no objection to sealing, (2) Epstein's counsel's verbal stipulation to temporarily s

D18-0762 LT Case No: 502009CA0408003C3C3CXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

, Respondents/Defendants. MOTION TO STRIKE UNAUTHORIZED AND INAPPROPRIATE "JOINDER" FILED BY NON-PARTIES Petitioner, Jeffrey Epstein, pursuant to Florida Rule of Appellate Procedure 9.300, moves to strike the "Joinder by Victims in Edwards' Motion for Partial Relief from Stay with Request for Expedited Consideration"

horizing sanctions 1 The symbol (A- ) refers to Mr. Epstein's Appendix to Emergency Petition for Writ of Cer

• IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. 4D09-2554 PALM BEACH COUNTY L.T. CASE NO. 2008 CF 009381A RESPONSE TO MOTIONS FOR APPE

not contain comparable language authorizing sanctions (PA-3). The new administrative order authorizing sanctions 1 The symbol (A- ) refers to Mr. Epstein's Appendix to Emergency Petition for Writ of Certiorari filed July 1, 2009, and (PA- ) refers to the Supplemental Appendix to the Post's Response

APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Res

ourt to impose an award of attorney's fees and costs as a sanction under the authority of 15th Judicial Circuit Administrative Order 2.303-9/08 and Florida Rule of Appellate Procedure 9.410. Neither supports an award of appellate fees and costs. 09/12/2079 I CONFPIT5E4NTIAL Agency to Agency Requet: 19-011 SDNY_GM_00

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Respondent. CASE NO. PALM BEACH LT. CASE NO. 2008 CF 009381A PETITIONER'S EMERGENCY MOTION TO REVIEW ORDER

y Disclosure of Federal Non-Prosecution Agreement and Addendum pending his contemporaneously filed petition for certiorari and grant the stay.' Mr. Epstein seeks review of the stay denial on emergency basis. The court stayed disclosure until noon on Thursday, July 2, 2009 so Mr. Epstein could seek revi

APPEAL OF THE STATE OF FLORIDA, FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, v. STATE OF FLORIDA, Res

iled petition for certiorari and grant the stay.' Mr. Epstein seeks review of the stay denial on emergency bas

GENCY MOTION TO REVIEW ORDER DENYING STAY OF DISCLOSURE OF FEDERAL NON-PROSECUTION AGREEMENT AND ADDENDUM Petitioner, JEFFREY EPSTEIN, pursuant to Florida Rule of Appellate Procedure 9.310(O, requests this Court review the order denying his Motion to Stay Disclosure of Federal Non-Prosecution Agreement and Addendum pen

F APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 Appellate Case No.: 4D18-0787 LT Case No: 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REQUEST FOR ORAL ARGUMEN

eleventh-hour misuse of Rule 1.440 in a maneuvering effort to achieve severance or bifurcation of his counterclaim from the original claim filed by Epstein. Oral argument would benefit this Court in reviewing why Edwards' tactical gambit 2 EFTA00808507 should not be permitted to effect a violation o

: 4D18-0787 LT Case No: 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

N, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REQUEST FOR ORAL ARGUMENT Petitioner, Jeffrey Epstein, pursuant to Florida Rule of Appellate Procedure 9.320, requests oral argument in the consolidated appeals (Case Nos. 4D18-0762 and 4D18-0787) and as grounds states: Petitioner respectf

ebecca Mercier Vargas Board Certified Appellate Lawyers MEMORANDUM TO: Robert Critton FROM: Jane Kreusler-Walsh cr S DATE: June 25, 2009 RE: Epstein: Motion to Stay You asked me to provide you with a brief summary of the law regarding stays pending appeal. Florida Rule of Appellate Procedure 9.3

cr S DATE: June 25, 2009 RE: Epstein: Motion to Stay You asked me to provide you with a brief summary of the law regarding stays pending appeal. Florida Rule of Appellate Procedure 9.310(a) allows the trial court to stay an order pending appeal. Whether to grant a stay is discretionary with the trial court. See Pabia