Epstein Secrets

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 Order of the Circuit Court of the Fifteen

ocess d. (4) Fraud e. (5) Conspiracy to Commit Fraud (App. 1). On December 21, 2009, just 17 days after Epstein instituted the civil proceeding, Edwards filed a Counterclaim for abuse of process against Epstein. (App. 2). Thereafter, Edwards amended his Counterclaim several times, ultimately allegi

ari, this Court recognizes that compliance with the mandatory nature of Rule 1.440 is so fundamental that it warrants mandamus relief. Id. at 421. The Second District also has recognized that strict compliance with Rule 1.440 is required, and has granted mandamus relief absent such compliance. See Gawker Media, L

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 Florida Rule of Appellate Procedure 9.310(0,

is case on August 9, 2010. (App. 5). 2 EFTA00793768 (App. 1). On December 21, 2009, just 17 days after Epstein instituted the civil proceeding, Edwards filed a Counterclaim for abuse of process against Epstein. (App. 2). Thereafter, Edwards amended his Counterclaim several times, ultimately allegi

cognizes that compliance with the mandatory nature of Rule 1.440 is so fundamental that it warrants mandamus relief. Id. at 421. 9 EFTA00793775 The Second District also has recognized that strict compliance with Rule 1.440 is required, and has granted mandamus relief absent such compliance. See Gawker Media, L

ion Motion Page 23 of24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite

strict Court of Appeals characterized as "a series of temporary injunctions without the necessary showing of entitlement to injunctive relief." Id. The Second District quashed the order granting the injunction and held that "[a]n injunction cannot be used to enforce money damages or prevent a party of disposing of

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

secution action brought by a physician against his patients and an expert after he successfully defended a malpractice claim. Also of significance is the Second District’s opinion in Olson v. Johnson, 961 So. 2d 351 (Fla. 2d DCA 2007). In that case, the court observed that the litigation (or judicial) privilege would no

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes