Epstein Secrets

ATE 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 EMERGENCY PETITION FOR WRIT OF MANDAMUS On Rev

n his Response that "the only reason the case was allegedly not at issue was Epstein's failure, over more than six years, to seek a default against Rothstein[.]" (Resp. at p. 1) [emphasis added]. However, at the March 8, 2018, hearing, Judge Hafele held Edwards equally responsible for the current Rule 1.

Epstein agreed and objected before trial occurred. Edwards' attempt to pigeon-hole this case to fit within the purview of Labor Ready Se. Inc. v. Australian Warehouses Condo. =, 962 So. 2d 1053 (Fla. 4th DCA 2007), and HSBC Bank USA,.. v. Serban, 148 So. 3d 1287 (Fla. 1st DCA 2014), is unavailing. In fact, the instant

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

, 18, 19, 20 148 So.3d 1287 (Fla. 1st DCA 2014) Jane Doe No. 1, et al. v. United States, 4 749 F.3d 999 (11th Cir. 2014) Labor Ready Se. Inc. v. Australian Warehouses Condo. ffi, 14, 16, 17 962 So.2d 1053 (Fla. 4th DCA 2007) Parrish v. Dougherty, 14 505 So.2d 646 (Fla. 1st DCA 1987) Pleus v. Crist, 22 14 So.3d 94

RICT 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 ARGUMENT Petitioner, Jeffrey Epstein, pursuant to F

gument because it will provide the necessary opportunity to fully discuss the applicable law, case history, and interrelationship of the Epstein v. Rothstein and Edwards claim with the Edwards v. Epstein malicious prosecution counterclaim (that was filed in the same action only days later in 2009). Oral

s are "at issue" and reported decisions from this Court and other appellate courts on the mandatory nature of the rule. See Labor Ready Se. Inc. v. Australian Warehouses Condo. Ass 'n, 962 So. 2d 1053 (Fla. 4th DCA 2007)(brought on final appeal, not mandamus, and therefore Rule 1.440 was "waived [by] the aggrieved party w

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

ke in this case—an amended pleading is filed subsequent to an otherwise compliant order setting_trial under Rule 1.440. See Labor Ready Se. Inc. v. Australian Warehouses Condo. Ass'n, 962 So. 2d 1053 (Fla. 4th DCA 2007). Labor Ready was another final appeal, not a mandamus proceeding. The appellant in that case argued tha