Jay Howell & Associates 644 Cesery Blvd., #250 Jacksonville, FL 32211 Co-Counsel for Intervenors E.W., and Jane Doe VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 14 EFTA00808469 LINK & ROCKENBACH, PA 1555 Palm Bea

ded). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was "factually . . . some overlap," and that he was "not suggesting [otherwise]." (App. 19, p. 222.) And no less than six times

bifurcating claims which involve interrelated factual issues because severance risks inconsistent outcomes.") (emphasis added). 8 EFTA00808463 Hafele concluded that the claim and counterclaim were not factually intertwined. (Response, p. 21). To the contrary, Judge Hafele acknowledged there was

ustralian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Epstein VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 11 EFTA00805468 LINK & ROCKENBACH, PA 1555 Palm Bea

xists, and the information finds its light of truth in a court. Until then, the documents are under seal and the "no dissemination" ruling by Judge Hafele has been fully complied with by Epstein and his counsel. The Record Truth is that the Extraordinary Documents Remain Under Seal and No Partial Rel

hat's not the issue. You've done your job." (App. D-2, 59:24.) Even though this Court's stay order did not occur for an entire 24 hours after Judge Hafele's oral ruling on March 8, 2018, Epstein and his counsel took into account that the attendance by the trial judge and counsel at the Palm Beach Count

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel hereby certify that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 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 13, 3 018. B~I

IMON STEVE IA EARTH 034N1 S STARK wALIDI A STEW HAND DELIVERY September 28, 2017 SEARCY DENNEY SCAROLA BARNHART s-SHIPLN. i/ The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Re: EDWARDS ADV. EPSTEIN Case No. 2009CA040800XXXMB O

205 N Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Re: EDWARDS ADV. EPSTEIN Case No. 2009CA040800XXXMB Our File No.: 291874 Dear Judge Hafele: Onhummantanat THE TOWLE HOUSE 517 NORTH CALPIMN STREET TALLAHASSEE. FL 32301.1231 Pursuant to Your Honor's Order, enclosed please find the foll

m from a disc that we started reviewing on February 25th, 2018? I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

urt matter. MR. SCAROLA: We are. MR. LINK: I may have misunderstood, because this is a bankruptcy declaration. And there isn't anything in Judge Hafele's order that talks about bankruptcy testimony or spoke that you can inquire about. Obviously, by signing this he has adopted every statement in t

, over more than six years, to seek a default against Rothstein[.]" (Resp. at p. 1) [emphasis added]. However, at the March 8, 2018, hearing, Judge Hafele held Edwards equally responsible for the current Rule 1.440 issue because Edwards was the party who 2 EFTA00808473 noticed the case for trial an

in Jack A. Goldberger Atterbury, Goldberger & Weiss, 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Eps

Atterbury, Goldberger & Weiss, P.A. Suite 1400 01 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein VIA U.S. MAIL ONLY The Honorable Donald W. Hafele 18 EFTA00793747 111111111 By: /s/ Kara Berard Rockenbach Scott J. Link (FRIse Kara Berard Rockenbach (FBN Rachel J. Glasser (FBN Primary: P

d Marine, Inc., 174 So. 3d 1037, 1039 (Fla. 15 EFTA00793744 4th DCA 2015) (emphasis added; citation and internal quotation marks omitted). Judge Hafele specifically cited this case and its holding at the March 8, 2018 hearing, but failed to explain how he could get around it. Again, "this matter,"

assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12

he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca

d the materials from Fowler White's files. According to the motion, during a March 8 hearing on the privileged communications, State Circuit Judge Donald W. Hafele said, "The critical question, though, is why did Fowler White have these documents, why were they continued to be held, and was it in violation eith

stein never even knew Fowler White had the disc until we found it." Counsel for three victims — identified as L.M., E.W. and Jane Doe — asked Judge Hafele to order Fowler White to explain its handling of the confidential documents, but he said he lacked the authority to do so since the firm had withdr

critics have called questionably lenient. According to the article, Florida's Fourth District Court of Appeals unanimously agreed that Circuit Judge Donald W. Hafele had erred when he ruled he had no authority to release the normally secret transcripts of the 2006 Palm Beach County proceedings. The court cited a

says grand jury records can be made public if that is a "furtherance of justice." The article stated that the court in Wednesday's decision ordered Hafele to review the transcripts and to release those he deems would further justice, redacting the names of victims, witnesses, and EFTA00160380 those

8XXXXMB AB Plaintiffs' Responses to Defendant's Motion for Leave to Serve Additional Interrogatories Hearing on May 12, 2010 O 8:45 AM Dear Judge Hafele: Enclosed please find EW's Responses to Defendant's Motion for Leave to Serve Additional Interrogatories set for May 12, 2010 at 8:45AM. Should yo

YH TO J U ST ICE COM Farmer, Jaffe, Weissing, Edwards, Fistos a Lehrman, P.L. May 10, 2010 VIA FEDEX PRIORITY OVERNIGHT 7935 2823 3787 Honorable Donald W. Hafele Main Judicial Complex Palm Beach County Courthouse 205 North Dixie Highway Room 11.1204 West Palm Beach, Florida 33401 Re: EW v. Jeffrey Epste

to the form, and in 15 MR. YAREMA: Object to the form. 15 addition this is irrelevant and has already 16 A Fifth. 16 been addressed by Judge Hafele as an 17 Q Have you ever physically touched C.L.? 17 inappropriate question. That's my 18 MR. YAREMA: Object to the form. 18 objection. 19

al Support (561) 835-0220 EFTA00181799 Page 5 33: L,8 grounds10:25 guess 95:4 guest58:3 95:19 guilty41:18 guise21:24 H habit30:23 57:19 Hafele 80:16 Hafele's81:6 68:7,14,19 70:8 74:24 75:5 half 7:19 HAIND100:17 hands45:20 hanging 93:21 happened 28:9 34:4 39:25 happening 84:6 hara

se or e en ant Scott Rothstein Plaintiff Bradley J. Edwards Jack A. Goldberger WA HAND DELIVERY Atterbu , Goldber er & Weiss, P.A. The Honorable Donald W. Hafele uite 1400 Palm Beach County Courthouse 1 205 N. Dixie Highway, Room 10.1216 o- outzse or amt minter- West Palm Beach, FL 33401 Defendant Jeffr

anxiety" and "emotional distress" he suffered as a result of Epstein's filing and continuation of this lawsuit. At the March 8, 2018 hearing, Judge Hafele himself recognized no less than six times that Edwards' counterclaim for malicious prosecution against Epstein had its 4 EFTA00793696 genesis in

l follow, addressing the severance order, and may be consolidated with the mandamus petition.' At the March 8, 2018 hearing, Epstein advised Judge Hafele of his intent to file the extraordinary writ petitions in this Court, and made an ore tenus motion for stay of the trial court proceedings pending

Atterbur , Goldber er & Weiss, P.A. Suite 1400 01 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein VIA U.S. MAIL ONLY The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 19 EFTA00793785 LINK & R KENBA H PA By: /s/ Kara B

review of summons and complaint. $425.00 1.5 $637.50: 11/26/2019 ow Review Reviewecj motion for pro hac vice and Judge $425.00 0.2 $85.00 Hafele' order granting 11i26/2019 ow Teleconference Teleconference w/ Clf_ent, re: response to lawsuit $425.00 0.5 $212.50 11/26/2019 ow Draft Dr

tal 11/26/2019 bw Review Initial review of summons and complaint. $425.00 1.5 $637.50 11/26/2019 DW Review Reviewed motion for pro hac vice and Judge Hafele' order granting $425.00 0.2 $85.00 11/26/2019 DW Teleconference Teleconference w/ Client, re: response to lawsuit $425.00 0.5 $212.50 11/26/2019 DW D

BURLINGTON ROCKENBACH June 26, 2014 Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 9.1215 West Palm Beach, FL 33401 Re: Epstein v. Rothstein Case No: 502009CA040800XXXXMB

County Courthouse 205 N. Dixie Highway, Room 9.1215 West Palm Beach, FL 33401 Re: Epstein v. Rothstein Case No: 502009CA040800XXXXMB Dear Judge Hafele: PHILIP M. BURLINGTON. BARD D. ROCKENBACSI• ANDREW A. HARRIS. NICHOLE J. SEGAL ADAM J. RICHARDSON • GOARD CERTIFIED IN APPELLATE PRACTICE GLORIA

the women claim Epstein, now 57, is responsible for their emotional distress, his attorneys can explore the impact of other events. Medical records, Hafele said, are a better source of information than a person's memory . Attorney Louis Silver, who represents the Presidential. Women's Health Center, a We

that they suffered psychological ills after being paid to give him sexually-charged massages at his Palm Beach mansion when they were as young as 14. Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records, he said, can't be sought until the women are asked whether th

ourt matter. MR. SCAROLA: We are. MR. LINK: I may have misunderstood, because this is a bankruptcy declaration. And there isn't anything in Judge Hafele's order that talks about bankruptcy testimony or spoke that you can inquire about. Obviously, by signing this, he has adopted every statement in

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

tal 11/26/2019 DW Review Initial review of summons and complaint. $425.00 1.5 $637.50 11726/2019 DW Review Reviewed motion for pro hac vice and Judge Hafele: order granting $425.00 0.2 $85.00 11/26/2019 DW Teleconference Teleconference w/ Client, re: response to lawsuit. $425.00 0.5 $212.50 11/26/2019 DW

0 10/16/2020 AU Meeting Discussed Pl’s-settlement proposal w/ DAW $475,00 0.2 $95.00 10/19'2020 DW Various Uploaded proposed order, re: CMC for Judge Hafele . ■ $425.00 0.1 $42,50 10/19'2020 DW Telephone Spoke w/ client, re: Pl's settlement proposal $425.00 0.2 $85.00 10/19/2020 DW Telephone Spoke w/ Pl's

in Judicial Complex Re: I v. Jeffrey Epstein / Case No. 502008CA028051XXXXMB AB -and- v. Jeffrey Epstein / Case No. 502008CP003626XXXXMB Dear Judge Hafele: Enclosed please find copies of Plaintiffs' proposed Agreed Orders concerning the hearing on Defendant, Jeffrey Epstein's Motion for Partial Summar

7 EFTA00612078 Class ,t, Cornrneroa t - -• 0 P.IP5TIC E.CONI Farmer, Jaffe, Weissing, Edwards, Fistos a Lehrman, P.L. May 7, 2010 Honorable Donald W. Hafele Main Judicial Complex Re: I v. Jeffrey Epstein / Case No. 502008CA028051XXXXMB AB -and- v. Jeffrey Epstein / Case No. 502008CP003626XXXXMB Dear Ju