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

127 (Fla. 2d DCA 2015); which is distinguishable. In Gawker, the plaintiff brought suit against multiple related defendants. One of the defendants, Blogwire, contested personal jurisdiction. That challenge resulted in an appeal. In the meantime, all other defendants had tiled answers and affirmative def

at challenge resulted in an appeal. In the meantime, all other defendants had tiled answers and affirmative defenses to the original claims. While Blogwire's appeal was pending, the plaintiff moved to sever the claims against Blogwire and to set the remaining claims for trial. Over the other defendants'

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

#1, having been dismissed from that Action long ago. Contending that Edwards could notice Action #1 for trial is equivalent to saying that defendant Blogwire in the Gawker case could have noticed the case there for trial after having been dismissed from the case. Therefore, Action #2 is more akin to a cr

Bollea 170 So. 3d 125 (Fla. 2d DCA 2015), the case primarily relied upon by Epstein, the plaintiff, Bollea, sued multiple defendants, one of whom, Blogwire, contested Florida's long arm-jurisdiction over it. After an initial unsuccessful attempt to sever the claims against Blogwire and go forward with a

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

rehearing, if any." Id. at 133 (emphasis added). Gawker, like this case, involved an action that was not at issue. Bollea dismissed one defendant, Blogwire, but amended to seek punitive damages against the remaining defendant. Determined to maintain the trial date, Bollea also filed a "notice that acti

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

rehearing, if any." Id. at 133 (emphasis added). Gawker, like this case, involved an action that was not at issue. Bollea dismissed one defendant, Blogwire, but amended to seek punitive damages against the remaining defendant. Determined to maintain the trial date, Bollea also filed a "notice that acti