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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
ear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compl
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
im which has neither been answered nor defaulted, then the entire action (excluding only crossclaims) is not at issue. See Fla. R. Civ. P. 1.440. 6 Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Ha. 5th DCA 2016) ("Strict compli
. 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
ear: "strict compliance with rule 1.440 is mandatory." Bennett v. Cont'l Chemicals, Inc., 492 So. 2d 724, 727 (Fla. 1st DCA 1986) (emphasis added). Accord Teelucksingh v. Teelucksingh, 21 So. 3d 37, 37 (Fla. 2d DCA 2009). See also Melbourne HMA, LLC v. Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compl
Entities connected to both Jeffrey Epstein and Accord Teelucksingh

George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Naomi Campbell
PERSON
Chris Tucker
PERSONPalm Beach County Courthouse
LOCATIONMarc S. Nurik
PERSON
Melbourne
LOCATION
Scott J. Link
PERSONDonald W. Hafele
PERSON
Bennett
PERSONNichole J. Segal
PERSONBurlington & Rockenbach
ORGANIZATIONFifteenth Judicial Circuit
ORGANIZATIONPetition
ORGANIZATIONHiggins
PERSONFOURTH DISTRICT
LOCATION