6
Shared Docs
6
Same-Page
12 / 6
Mentions
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
emicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A. 1 204 So.3d 476 (Fla. 4th DCA 2016) Gawker Media, LLC v. Bollea 20, 21, 22 170 So.3d 125 (Fla. 2d DCA 2015) Grossman v. Fla. Power & Light Co., 14 570 So.2d 992 (Fla. 2d DCA 1990) Haft v. Adams, 1 238 So.2
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
Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006)(issuing a writ of mandamus to enforce strict toning of Rule 1.440(c)); 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, including its mandate
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
69, 170 (Ha. 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, including its mandat
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
.A., 204 So. 3d 476, 479 (Fla. 4th DCA 2016) (citing Genuine Parts Co. v. Parsons, 917 So. 2d 419, 421 (Fla. 4th DCA 2006) and Gawker Media, LLC v. Bollea, 170 So. 3d 125, 130 (Ha. 2d DCA 2015)). I In compliance with this Court's Administrative Order No. 2014-1, the Petitioner has contemporaneously fi
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
9, 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, including its mandat
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
or versus Bolloa District, as far as the Court is concerned, is the Labor Ready Southeast, Inc. versus Australian Warehouses Condominium 4 case. Bollea, if I recall correctly, is A Association case. But not so much for the S Hulk Hogan from wrestling. Court's position that it's taking as it 6
Entities connected to both Scott Rothstein and Bollea

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONPalm Beach Lakes Boulevard
LOCATION
Donald Trump
PERSONMarc S. Nurik
PERSONGoldberger & Weiss
ORGANIZATION
Scott J. Link
PERSONPalm Beach County Courthouse
LOCATIONNichole J. Segal
PERSONBurlington & Rockenbach
ORGANIZATION
Searcy
PERSONDonald W. Hafele
PERSONKara Berard Rockenbach
PERSONFOURTH DISTRICT
LOCATIONFlorida Rule of Civil
ORGANIZATION