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e modeling industry? Image via Models Jeffrey Epstein Pedophile Billionaire and his Sex Den [TDB] EFTA01482121 A Sex-Crime Investigation Reveals Jeffrey Epstein's Dangerous Dream World [New York] Earlier: Pervy Billionaire May Have All The Sex-Trafficking Defense Money Can Buy Why Superrich Guys Feel Entitl
background investigation. Full research was conducted on MC2 Models Management LLC in NY only. Media research was conducted on Jeffrey Epstein and J Epstein and Co. Throughout this search, the following records were researched: Company and corporate records, RDC (Regulatory Data Corp), MIS (McDonald In
in connection with child trafficking: Probe of the convicted billionaire widens to include a famous modeling agency. The FBI is also investigating Epsteins friend Jean Luc Brunel, whose MC2 modeling agency allegedly appears to have been a source of young girls from overseas who ended up on Epsteins pri
s allege that young girls from South America, EFTA01482119 Europe, and the former Soviet republics, few of whom spoke English, were recruited for Esptein's sexual pleasure. According to a former bookkeeper, a number of the girls worked for MC2, the modeling agency owned by Jean Luc Brunel, a longtime
LLC", "YHS LLC", "I Correct com LLC", "The 2007 Jeffrey E Epstein Insurance Trust 1 Dtd November 1 2007" an
the justified prosecution of his claims against Mr. Epstein," Scarola said. Edwards secured deals for victim
zebel Jezebel August 4, 2010 Wednesday 1:00 PM EST LENGTH: 1373 words HEADLINE: The Sex-Trafficking Model Scout [Predators] BODY: Aug. 4, 2010 (Gawker Media delivered by Newstex) Jeffrey Epstein, the billionaire financier who the FBI believes molested around 40 underaged girls, was assisted by a promine
lly, Respondents/Defendants. EMERGENCY MOTION FOR REVIEW OF ORDER DENYING STAY Pursuant to Florida Rule of Appellate Procedure 9.310(0, Petitioner Jeffrey Epstein, the plaintiff/counter-defendant below, files this motion for review of the circuit court's Order entered March 8, 2018 denying a stay of trial cour
(the Honorable Donald Hafele) has just made two rulings which warrant extraordinary relief. The first ruling in an Order of March 8, 2018, denying Epstein's Motion to Remove Case from Trial Docket in I In compliance with this Court's Administrative Order No. 2014-1, the Petitioner has contemporaneousl
Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
arately. (App. 19)6. The court denied Epstein's ore tenus motion for stay. and this motion for review of that denial follows. (App. 20). ARGUMENT I. EPSTEIN IS LIKELY TO SUCCEED ON THE MERITS OF HIS MANDAMUS PETITION BECAUSE THE CIRCUIT COURT MUST REMOVE THE CASE FROM THE TRIAL DOCKET IN ORDER TO COMPL
nscript. Epstein will supplement his Appendix with the Court's Order once entered. 7 See Bennett, 492 So. 2d at 727; Teelucksingh, 21 So. 3d at 37; Gawker Media, LLC, 170 So. 3d at 131; Genuine Pans Co., 917 So. 2d at 421. 7 EFTA00793773 The purpose of mandamus is "to enforce the respondent's unqualified
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762
Background Facts 4 Epstein Attempts to Intimidate His Victims by Filing Suit Against and 5-11 Retaliates Against their Lawyer ARGUMENT 12-26 EPSTEIN'S PETITION FOR WRIT OF MANDAMUS SHOULD BE DENIED BECAUSE EPSTEIN WAITED UNTIL THE EVE OF TRIAL, MORE THAN TEN MONTHS AFTER THE CASE HAD BEEN SET F
APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually,
ision AG of anything whatsoever having to do with Mr. Epstein's prosecution of that one-count Complaint agains
ett v. Continental Chemicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A. 1 204 So.3d 476 (Fla. 4th DCA 2016) Gawker Media, LLC v. Bollea 20, 21, 22 170 So.3d 125 (Fla. 2d DCA 2015) Grossman v. Fla. Power & Light Co., 14 570 So.2d 992 (Fla. 2d DCA 1990) Haft v. Adam
ockenbach FBN Rachel J. Glasser Primary: Primary: Primary: Seconda Seconda Seconda Trial & Appellate Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman
cing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All background information is derived from the complaints and Jo
Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
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 Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015) ("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440, inclu
. Link & Rockenbach, PA A ellate Counsel for Petitioner EFTA00793730 INTRODUCTION In this Emergency Petition for a writ of mandamus, Petitioner Jeffrey Epstein, the plaintiff/counter-defendant below, challenges the circuit court's Order entered March 8, 2018, by the Honorable Donald Hafele, denying Epstein'
Epstein, the plaintiff/counter-defendant below, challenges the circuit court's Order entered March 8, 2018, by the Honorable Donald Hafele, denying Epstein's Motion to Remove Case from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440. Epstein requests Emergency treatment because
Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
. Wells Fargo Bank, N.A., 204 So. 3d 476, 479 (Fla. 4th DCA 2016) (citing Genuine Parts Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006) and Gawker Media, LLC v. Bollea, 170 So. 3d 125, 130 (Ha. 2d DCA 2015)). I In compliance with this Court's Administrative Order No. 2014-1, the Petitioner has cont
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. REPLY TO RESPONSE TO EME
Civil Procedure, and unequivocal legal precedent interpreting the same clearly against him, Edwards levels false and misleading accusations against Epstein and injects impertinent allegations into his argument in an obvious attempt to divert the Court from its inevitable decision. Throughout his Respon
18-0762 LT Case No: 502009CA0408003C3C3OCNIB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST
also Tucker, 175 So. 3d at 306 13 EFTA00808484 (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Gawker Media, LLC, 170 So. 3d at 129-30 (granting mandamus to enforce Rule 1.440 and holding that an appeal after final judgment would be insufficient to remedy
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
ance"); Genuine Pans Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006)(issuing a writ of mandamus to enforce strict toning of Rule 1.440(c)); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015)("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440, includ
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTE
STEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440 Counter-Plaintiff Edwards, by and through un
OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv
at all of the claims or counterclaims in those cases involved the same parties that were involved in the underlying complaint. 10. For example, in Gawker Media, LLC v. Bollea 170 So. 3d 125 (Fla. 2d DCA 2015), the case primarily relied upon by Epstein, the plaintiff, Bollea, sued multiple defendants, one of
Entities connected to both Jeffrey Epstein and Gawker Media

George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Naomi Campbell
PERSONGoldberger & Weiss
ORGANIZATION
Chris Tucker
PERSON
Lauderdale
LOCATIONPalm Beach Lakes Boulevard
LOCATIONPalm Beach County Courthouse
LOCATIONMarc S. Nurik
PERSON
Melbourne
LOCATION
Scott J. Link
PERSON
Searcy
PERSONDonald W. Hafele
PERSON
Bennett
PERSONKara Berard Rockenbach
PERSON