Epstein Secrets

/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, Jeffrey Epstein, (her

nt. DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Plaintiffs Second Amended

Complaint. Robert D. •ritton, Jr. Attorney f r Defendant Epstein Certificate of Se ce I HEREBY CERTIFY that a t

9-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT's MOTION FOR EXTE

522 Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 3 of 4 Jane Doe No. 2 v. Epstein Page 3 Defendant to respond to the Second Amended Complaint. Robert D. •ritton, Jr. Attorney f r Defendant Epstein Certificate of Se ce I HEREBY CERTIFY that a true copy of the foregoing was electronicall

lialonancto aoiaaans 9698922 : fiq VIOS EFTA00307083 FOR PUBLICATION IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING, INC., Plaintiffs, Defendant. DENISE FRANCOIS, ESQ. Hodge & Francois 1340 Taameberg St. Thomas, U.S. V

2 is the sole member of Plaintiff L.S.J., LLC. L.S.J.3 owns Little St. James, which is an island off of the southeast coast of St. Thomas. In 2005, Epstein contracted with non-parties—J.P. Molyneux Studio, Ltd., and Juan Pablo Molyneux (collectively, "Molyneux")—to design a residential project on Little

Renaissance exchanged phone calls, faxes and emalls with s in :Bd e8S:00 TT -1.2-90 HU373/120103 aolHudns 0690912 : fiq Was xed EFTA00307088 Jetey Epstein v. Fancelli Paneling Inc. Civil No. ST-10-CV-443 Memorandum Opinion Page 6 of II foreign corporation engages in reciprocal communications with a

GIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC., v. FANCELLI PANELING,

ecide to assert against Molyneux Studio; and it is further ORDERED that Plaintiffs Jeffrey Epstein and L.S.J., LLC, shall file proof of service of the Second Amended Complaint on Molyneux Studio within thirty (30) days of filing the Second Amended Complaint; and it is further ORDERED that copies of this Order shall be dir

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

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,

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

longer applied. Mr. Edwards pointed out to this Court and to Mr. Epstein -- he is absolutely correct -- that Mr. Epstein's operative complaint is the Second Amended Complaint to which there is no default. What rule 2.440 tolls this Court to do is to look at the time that Mr. Edwards moved -- it's maybe a notice to set

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

15 EFTA00808533 C. Epstein Waived the Right to Rely on Rule 1.440 Epstein has waived reliance on Rule 1.440. As discussed above, Epstein filed the Second Amended Complaint on August 22, 2011. Rothstein never answered the complaint. Pursuant to Rule 1.500(a), Florida Rules of Civil Procedure, it was incumbent upon Epst

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

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

. 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

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

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

ded Complaint, which was filed on August 21, 2011. 4. Edwards, however, is not a party to that case as Epstein voluntarily dismissed Edwards from the Second Amended Complaint on August 16, 2012.' That point alone nullifies Epstein's entire argument that Edwards' Motion to Set Case for Trial was not ripe. Rule 1.440(b), o

Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through hi

-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby moves to dismiss the Amended Counterclaim of the Defendant/Counter-Plaintiff, BRADLEY EDWARDS ("E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

ended Complaint which contained a single count against Edwards for abuse of process, and a single count against Rothstein. Edwards moved to dismiss the Second Amended Complaint. At the September 28, 2011 hearing on Edwards' motion to dismiss the Second Amended Complaint, the Court explained that abuse of process required -