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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.
final judgment would be insufficient to remedy the rule's provisions t re q g -in a 50-day hiatus between trial and service of the last pleading); Precision Constructors, Inc., 825 So. 2d at 1063 (judgment vacated because failure to adhere strictly to the mandates of Rule 1.440 is reversible error). Absent mandamus relie
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
Y. Mellon, 175 So. 3d 305, 306 (Fla. 3d DCA 2014) (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Precision Constructors, Inc. v. Yalta: Constr. Corp., 825 So. 2d 1062, 1063 (Fla. 3d DCA 2002) (judgment vacated because failure to adhere strictly to the mandates of Rule 1.44
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
Y. Mellon, 175 So. 3d 305, 306 (Fla. 3d DCA 2014) (final judgment reversed because case noticed for trial before answer to counterclaim was filed); Precision Constructors, Inc. v. Vallee, Constr. Bifurcation is improper here, because the issues presented by the claim and counterclaim are so inextricably intertwined that it
Entities connected to both Scott Rothstein and Precision Constructors, Inc.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSON
George W. Bush
PERSON
Donald Trump
PERSONMarc S. Nurik
PERSON
Scott J. Link
PERSONPalm Beach County Courthouse
LOCATIONNichole J. Segal
PERSON
Searcy
PERSONBurlington & Rockenbach
ORGANIZATIONDonald W. Hafele
PERSONFOURTH DISTRICT
LOCATIONFlorida Rule of Civil
ORGANIZATION
Naomi Campbell
PERSONDenny
PERSONShipley
PERSONMark Nurik
PERSON
Chris Tucker
PERSON