Epstein Secrets

afele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack Scarola, Esq. Karen Terry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL

GENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes

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'

e E-Mails: ; and Primary E-Mail: Searcy Denney Scarola Bamhart & Shipley, 2139 Palm Beach Lakes Bouleva

#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

93746 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 8'h day of March, 2018: Jack Scarola Sears , Denn , Scarola, Barnhart & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. and i 350 Co-Counsel for Defendant/Counter-Pla

E I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 8'h day of March, 2018: Jack Scarola Sears , Denn , Scarola, Barnhart & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. and i 350 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwar

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

0793784 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Motion was furnished via email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, P.A. 350 1 o- ounse or

shed via email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-

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