IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
CASE NO. 4D18-0762
JEFFREY EPSTEIN,
RECEIVED, 3/13/2018 5:06 PM, Clerk, Fourth District Court of Appeal Petitioner,
-VS-
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually, and
L.M., E.W., and JANE DOE,
Intervenors.
Respondents
/
VERIFIED MOTION FOR ADMISSION TO APPEAR
PRO HAC VICE PURSUANT TO FLORIDA RULE OF
JUDICIAL ADMINISTRATION 2.510
Intervenor/respondents L.M., E.W., and Jane Doe (hereinafter "the
victims"), by and through its undersigned counsel, hereby moves this Honorable
Court to allow Paul G. Cassell ("Movant") to appear as counsel for the victims in
this Epstein v. Edwards case and represents the following:
1. Movant resides in Salt Lake City, Utah.
2. Movant is an attorney and employed as a professor of law at the S.J.
Quinney College of Law at the University of Utah. As permitted by University of
EFTA00807546
Utah regulations, Movant undertakes some private representations as well as pro
bono representations.
3. Movant has been retained personally to, in conjunction with other attorneys,
provide legal representation to three child sexual assault victims of Jeffrey Epstein,
who will be referred to pseudonymously as L.M., E.W., and Jane Doe in
connection with various Epstein- related litigation, including Jane Doe v. Epstein,
No. 9:08-cv-80893-Marra/Johnson (S.D. Fla.); Jane Doe 1 & 2. v. United States,
No. 9:08-cv-80736-KAM (S.D. Fla.)). Movant has been Admitted pro hac vice in
both of the above-described cases and worked with other Florida attorneys in
providing this representation. Movant has also been admitted pro hac vice in the
proceedings below.
4. Movant is an active member in good standing and currently eligible to
practice law in Utah (bar number 6078).
5. There are no disciplinary proceedings against Movant.
6. Within the past five years, Movant has not been subject to any disciplinary
proceedings.
7. Movant has never been subject to any suspension proceedings.
8. Movant has never been subject to any disbarment proceedings.
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9. Movant, either by registration, withdrawal, or otherwise, never has
terminated or attempted to terminate Movant's office as an attorney in order to
avoid administrative, disciplinary, disbarment, or suspension proceedings.
10. In the last five years, Movant has filed a motion to appear as counsel in
Florida state courts in the proceedings below and in Edwards v. Dershowitz, Case
NO.: CACE 15-000072 (Circuit Ct. of the nth Judicial Circuit in and for Broward
County, Florida) (motion granted).
11. Movant is not an inactive member of The Florida Bar.
12. Movant is not now and has never been a member of The Florida Bar.
13. Movant is not a suspended member of The Florida Bar.
14. Movant is not a disbarred member of The Florida Bar nor has Movant
received a disciplinary resignation from The Florida Bar.
15. Movant has not previously been disciplined or held in contempt by reason of
misconduct committed while engaged in representation pursuant to Florida Rule of
Judicial Administration 2.510.
16. Local counsel of record associated with Movant in this matter is Attorney
Jay Howell, a member of the Florida Bar who has represented L.M., E.W., and
Jane Doe, and maintains his practice in Jacksonville, Florida.
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17. Movant has read the applicable provisions of Florida Rule of Judicial
Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and
certifies that this verified motion complies with those rules.
18. Movant agrees to comply with the provisions of the Florida Rules of
Professional Conduct and consents to the jurisdiction of the courts and the Bar of
the State of Florida.
WHEREFORE, Movant respectfully requests permission to appear in this
court for the Epstein v. Edwards case.
DATED this 13th day of March, 2018
Is/ Paul G. Cassell
PAUL G. CASSELL
S.J. Quinney College of Law at the University
of Utah
383 S. University St.
Salt Lake City, UT 84112
(801) 585-5202'
[email protected]
Utah Bar #6078
I This daytime business address is provided for contact purposes only and is not intended to imply institutional endorsement by the University of Utah.
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CERTIFICATE OF LOCAL COUNSEL
I hereby consent to be associated as local counsel of record in this cause pursuant
to Florida Rule of Judicial Administration 2.510.
DATED this 13ih day of March, 2018.
JA HOWELL
Jay Howell & Assoc' tes
Florida Bar No.: 225657
Attorney E-Mail(s):
644 Cesery Blvd. #250
32211
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CERTIFICATE OF E-FILING AND SERVICE
Counsel hereby certify that this Motion to Appear Pro Hac Vice has been e-
filed and 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 • unsel on the attached service list, by email, on March 13, 2018.
By
JAY L
Jay Howell & Associates
Florida Bar No.: 225657
Attorney E-Mail(s)
644 Cesery Blvd. #250
Jacksonville, FL 32211
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📷 Images in this document (6 detected)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image is a page from a legal document, specifically a court order or a motion. The text is written in English and includes numbered paragraphs with headings such as "Movant" and "Respondent." There are references to legal terms such as "Clerk," "Court," and "Counsel." The document appears to be related to a legal proceeding, possibly a motion for relief from a stay or a motion for summary judg
[Image 2] The image shows a page from a legal document, specifically a court order or judgment. The text is written in English and includes numbered paragraphs with headings such as "Utah laws," "Movant's motion," and "Movant's motion for relief." There are references to legal cases and citations to statutes and court decisions. The document appears to be a formal legal document, possibly related to a legal
[Image 3] The image is a document scan, specifically a court document. It appears to be a motion or a notice of filing, as indicated by the text. The document is addressed to Scott Brownstein, Bradley J. Lonergan, and Jane Doe. The text mentions a case number and a date, but the specific details are not fully visible. The document is from the District Court of Appeal of the State of Florida, Fifth District.
[Image 4] The image shows a document with text, which appears to be a legal or official document. The text is in English and includes numbered paragraphs with headings such as "17. Movant has read the applicable provisions of Florida Statutes and Rules of Court." There are also references to "Movant," "Movant's Motion," and "Movant's Amended Motion." The document is dated "10th day of March, 2013," and it m
[Image 5] The image shows a document that appears to be a certificate of filing and service. It is a formal document with a header that includes the name of the court and the case number. The body of the document contains a statement indicating that a motion for summary judgment has been filed by the plaintiff in the case of "Apple Inc. v. Samsung Electronics Co., Ltd." The document is signed by a person wh
[Image 6] The image shows a document, which appears to be a certificate of local counsel. The document is a formal letter addressed to an individual named Jay Bowbell, with a Florida address provided. The letter is dated March 25, 2010, and it is signed by an individual whose name is not fully visible. The document includes a reference number and mentions a case number. The text is printed in black ink on a