Epstein Secrets

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 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY S

ember 7, 2009, while Edwards was pursuing the cases noted above on behalf of his clients, Epstein filed the original Complaint here against Edwards, Scott Rothstein ("Rothstein"), and one of Edwards' clients, designated as ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases

ld not be entitled to enforce the rule under the circumstances of this case. Epstein relies almost exclusively on the Second District's decision in Gawker Media, LLC v. Baal, 170 So.3d 125, 127 (Fla. 2d DCA 2015); which is distinguishable. In Gawker, the plaintiff brought suit against multiple related

1.440 Action #1 — Epstein v. Rothstein (Second Amended Complaint), 3. First, Epstein has a claim for Conspiracy to Commit Abuse of Process against Scott Rothstein. That claim is pled in the Second Amended Complaint, which was filed on August 21, 2011. 4. Edwards, however, is not a party to that case as Epste

s involving different parties and different claims, and it is undisputable that Edwards' action against Epstein for Malicious Prosecution, to which Rothstein is not a party, is at issue. EFTA00808651 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Rem

XMBAG 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 II. Gawker is simply inapplicable here. The Fourth Amended Counterclaim is an independent action filed after Edwards was dismissed from Action #1 (a necessary

EAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. PETITION FOR WRIT OF CERTIORARI On Review of a Non-Final Order of th

underlying all counts were interrelated). BACKGROUNDS This unique and complex case arose from the 2009 implosion of the Fort Lauderdale law firm Rothstein, Rosenfeldt & Adler, where defendant/counter- plaintiff Bradley Edwards worked and held himself out as a partner. The principal of the firm, defenda

is an insufficient remedy. As the Second District explained in Gawker Media, LLC v. Bollea, 170 So. 3d 125 (Fla. 2d DCA 2015): It is true that the Gawker defendants have available to them the legal remedy of pursuing an appeal from any future final judgment, in which they could complain of the erran

EAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review of a Non-Final Ord

Epstein filed his initial Complaint in this action against Scott Rothstein, Bradley Edwards and L.M.'- Epstein alleged the following counts against Rothstein: a. (1) Violation of § 772,101 — Florida Civil Remedies for Criminal Practices Act b. (2) Violation of § 895.01 — Florida's RICO Act c. (3) Abuse

Schoof, 190 So. 3d 169, 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,

EAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY MOTION FOR REVIEW OF ORDER DENYING STAY Pursuant to Florid

Epstein filed his initial Complaint in this action against Scott Rothstein, Bradley Edwards and L.M.3 Epstein alleged the following counts against Rothstein: a. (1) Violation of § 772,101 — Florida Civil Remedies for Criminal Practices Act b. (2) Violation of § 895.01 — Florida's RICO Act c. (3) Abuse

Schoof, 190 So. 3d 169, 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,

at 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, individually; 7 engage in an inordinate amount of time to BRADLEY EDWARDS, individually, 8 the exclusion of other natters that needed Defendan

ion for trial on May 24th, 2017. There is no dispute. And Mr. Edwards has actually pointed it out, Mr. Epstein did not have a default against Mr. Rothstein. Contrary to what Mr. Edwards' suggestion is, is to cure this issue -- 10 THE COURT: Mr. Epstein did not have a 11 default against Mr. Rothstein

OURT: Despite the representation, 29 The law says, in rule 1.440 in the 29 Ms. Rockenbach, that you made in your motion 24 Bennett case and the Gawker case from the 24 to continue, that Plaintiff and his trial 15 Second DCA, says that this Court has to look 25 counsel will not seek another con

ote in April. “Though her LinkedIn page claims a certificate in Swedish massage, there is no evidence that she ever actually treated Epstein to one,” Gawker (in the most straightforward and clearest reporting on the documents to date) wrote last week. And the National Enquirer did not appear to rely on th

m bringing some of those cases employed a young lawyer named Bradley Edwards, who managed some of the cases. In 2009, a founding partner at the firm, Scott Rothstein, fled the country before ultimately returning to plead guilty of running a $1.2 billion Ponzi scheme built around recruiting investors to buy stakes

uilt around recruiting investors to buy stakes in litigation settlements that turned out to be phony. As details of the fraud emerged, Epstein sued Rothstein and Edwards in Palm Beach County Court for racketeering, alleging, among other things, that they dangled Bill Clinton’s association with Epstein as a

ote in April. “Though her LinkedIn page claims a certificate in Swedish massage, there is no evidence that she ever actually treated Epstein to one,” Gawker (in the most straightforward and clearest reporting on the documents to date) wrote last week. And the Nationa/ Enquirer did not appear to rely on th

m bringing some of those cases employed a young lawyer named Bradley Edwards, who managed some of the cases. In 2009, a founding partner at the firm, Scott Rothstein, fled the country before ultimately returning to plead guilty of running a $1.2 billion Ponzi scheme built around recruiting investors to buy stakes

uilt around recruiting investors to buy stakes in litigation settlements that turned out to be phony. As details of the fraud emerged, Epstein sued Rothstein and Edwards in Palm Beach County Court for racketeering, alleging, among other things, that they dangled Bill Clinton’s association with Epstein as a