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30 Marc S. Nurik, Esq. LAW OFFICES OF MARC S. NURIK One E. Broward Boulevard, Ste. 700 Ft. Lauderdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, Ste. 2 Ft. Lauderdale. FL 33301-3268 Attormeys for Bradley J. Edwards EFTA00808548
on and the procurement of minors to engage in prostitution and further agreed to be registered as a sex offender (App.13, p.133). Bradley Edwards ("Edwards") is a civil attorney who represented multiple victims of Epstein's serial abuse of children. Edwards filed three civil actions against Epstein in
derdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, St
, 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
ellate 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 Review of a Non-Final Order of the Circuit
Confronted with Rule 1.440, a compulsory rule of Florida Civil Procedure, and unequivocal legal precedent interpreting the same clearly against him, Edwards levels false and misleading accusations against Epstein and injects impertinent allegations into his argument in an obvious attempt to divert the C
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
gument in his consolidated appeals from Judge Donald Hafele's March 8, 2018 rulings which resulted in two non-final orders, (1) granting Respondent Bradley J. Edwards' Motion for Separate Trials and (2) denying Petitioner's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate in Rule 1.440.
"exempts only cross-claims from the determination of when an action is at issue."). The issues raised in these consolidated appeals were created by Edwards' eleventh-hour misuse of Rule 1.440 in a maneuvering effort to achieve severance or bifurcation of his counterclaim from the original claim filed b
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
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
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
Entities connected to both Bradley Edwards and Australian Warehouses Condo

Jeffrey Epstein
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Donald Trump
PERSONPalm Beach Lakes Boulevard
LOCATIONGoldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Lauderdale
LOCATION
Scott J. Link
PERSON
Naomi Campbell
PERSONPalm Beach County Courthouse
LOCATIONDonald W. Hafele
PERSON
Searcy
PERSON
Melbourne
LOCATIONNichole J. Segal
PERSONBurlington & Rockenbach
ORGANIZATIONKara Berard Rockenbach
PERSONFlorida Rule of Civil
ORGANIZATION