EFTA01128837.pdf

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO. 502009CA040800XXXXMBAG Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually and L.M., individually, Defendant(s). NOTICE OF PROBABLE CONFLICT, MOTION TO CONTINUE FOR DATE CERTAIN IN FEBRUARY COMES NOW Jeffrey Epstein, through his undersigned counsel and gives the above Notice and would state as follows: 1. The matter is presently set for trial beginning October 28, 2013 for an eight week trial period. 2. The undersigned is the attorney that will conduct the actual trial of this matter. 3. There are conflicts that exist criminal trials that may prevent the undersigned's ability to try this matter during the period set. 4. That trial schedules and conflicts are now occurring, inter alia, due to resets of other conflicts of either counsel or Court, and are being presently set and will run into this period. 5. The undersigned on 23 September is beginning a multiple defendant 250 count "IRS" criminal trial in the United States District Court in Miami, which will take at least two to three weeks to try [United States v. Hachem, et al, Case Number 11-2083ICR-Williams]. 6. On October 18, 2013, the same date as the calendar call in this matter and at the same time, the undersigned has a calendar call before United States District Court Judge Marra in West Palm Beach to determine which date in that two week trial period he will begin trial in United States v. Daoud, et al, Case Number: 12-60205CR-Marra, an obstruction and perjury Indictment arising out of occurrences in the Scott Rothstein ponzi scheme, which coincidentally is an issue in the case Page 1 of 3 EFTA01128837 at bench. That case will take a week to try if the co-defendant pleads guilty. Judge Marra's schedule, due to the length of George brothers "pill mill" case and the "psychic" case presently being tried, has been somewhat in a state of flux. 7. The undersigned is then presently scheduled to try, inter alia, United States v. Berman, et al, Case Number: 13-60156CR-Zloch in the Southern District of Florida, a multiple defendant, multiple count business opportunities fraud and conspiracy matter that will take about a month to try, beginning on November 8, 2013. All co-counsel are planning on that date. 8. The undersigned is next set to try, again before Judge Marra, United States v. Antonaras, Case Number: 13-8000ICR-Marra, a bank fraud, mortgage fraud trial, set for December 6, 2013 for a two week docket, which also will take a week or more to try. 9. The undersigned is set on 21 October in the Circuit Court in Broward County in a capital murder case, State of Florida v. Bilotti, et al, Case Number: 08-3720CF10A, which is a potential trial due to severance issues and availability of other counsel, as the Judge prefers to try the non death defendants before the undersigned's client, however the non death defendants counsel are in trial. 10. The undersigned has two separate Racketeering [RICO] trials pending in the Circuit Court in Palm Beach County State of Florida v. Squillante,et al, Case Number: 2012-CF-008805- DXXX-MB [a drug racketeering conspiracy matter] and State ofFlorida v. Gali, et al, Case Number: 2010CF010982BMB [a Government program fraud conspiracy with numerous substantive acts], which are due to be tried. A calendar call in Gall is set before Judge Rosenberg on 16 September, and a calendar call before Judge Kelley on Squillante on 19 September. Since, due to a specially set Federal trial [Hachern], the undersigned cannot try the above cases, it is expected they will "roll" into the trial period for this matter. The prosecutor on Gall has suggested sometime in October for as a particular dialect of Arabic translator is needed for the informant, and has to be arranged. 11. Similarly the undersigned has another murder case set for 7 October in the Circuit Court in Broward County, State of Florida v. Mallet, Case Number: 11-11544CF10A which will similarly have to be continued due to the Hachern trial and which the undersigned expects that to be set in the present trial period for the instant case if undersigned were available. 12. The undersigned is already specially set for January 21, 2014 on a Defendant who has Page 2 of 3 EFTA01128838 been in custody for almost five years [State of Florida v. Terrelonge, et al, Case Number: 08- 13463CF1013]. Also, the undersigned will be away January 13, 2014 through January 17, 2014 at a seminar which has been pre-arranged and pre-paid. 13. The undersigned would, since February 2014 is presently clear, ask that this matter be set in February 2014 for trial. I HEREBY CERTIFY that a copy of the foregoing was furnished via Email to all counsel listed below, this 1 l'h day of September, 2013. FRED HADDAD, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, Florida 33394 Tel: Fax: By: FRED HADDAD Florida Bar No. 180891 COUNSEL LIST Jack Scarola, Esq. E-mail: Jack Goldberger, Esq. E-mail: Marc Nurik, Esq. E-mail: Bradley J. Edwards, Esq. E-mail: Tonja Haddad Coleman, Esq. E-mail: Lilly Ann Sanchez, Esq. E-mail: Page 3 of 3 EFTA01128839