Epstein Secrets

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), su

FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), submits this Response in

inconceivable what relevance Ms. deposition has to claim for punitive damages if she has no knowledge of her. In addition, Ms. testified that: a. Epstein never used physical force or coercion, nor made any threats against her. Id. at 252-53; b. She was never afraid or concerned for her safety. Id: c

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPO

finding of insufficient evidence [ J constitute[d] a departure from the essential requirements of the law." Id. See also Cypress Aviation, Inc. v. Bollea, 826 So. 2d 1091, 1092 (Fla. 2d DCA 2002) (holding that "Florida law is clear" that a plaintiff must provide the court with an evidentiary basis bef

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

9, 170 (Fla. 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, including its mandat

3 i 2 3 THE COURT: Good morning. Have a seat. Thank you. Needless co say the recent barrage, as 3 4 opposed to flurry, of activity that has JEFFREY EPSTEIN, S transpired is of extreme consternation to Plaintiff/Counter-Defendant, vs. 4 the court. It has caused me to have to SCOTT ROTHSTEIN, indivi

ck. So I look forward to discussing the privileged nature of the documents. And I thank Hr. Cassell for being here today. Your Honor, this is Mr. Epstein's motion to remove this case from the trial docket. It was prompted by Mr. Edwards' motion to separate the trials, which was motion -- for the ob

31:18,19 38:16 41:20 57:14 81:8 81:25 84:3 88:20 iteration 36:8,23 73:12 79:4 iterations 43:8 51:9 J 2:6 JACK 2:9,18 JAMES 2:13 Jane 2:12 Jeffrey 1:5 2:16 joined 30:2 joint 10:2044:25 JR 2:10 judge 1:164:14 7:23 8:2,17 9:3 15:19 21:21 29:11 30:1,2,3 36:16 40:14,22,22 41:6 41:17 43:25 4

assell for being here today. Your Honor, this is Mr. Epstein's motion to remove this case from the trial doc

or versus Bolloa District, as far as the Court is concerned, is the Labor Ready Southeast, Inc. versus Australian Warehouses Condominium 4 case. Bollea, if I recall correctly, is A Association case. But not so much for the S Hulk Hogan from wrestling. Court's position that it's taking as it 6

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

emicals, 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. Adams, 1 238 So.2

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

69, 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, including its mandat

. 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

.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 contemporaneously fi

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

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, including its mandate