EFTA01198613Set 9
2013-07-1749p10,885w
ULTIMATE
LOCK SYSTEMS, a Texas Corporation; DARREN
BAYSINOER, individually; RON DANIELS,
individually; and JOSEPH TITONE, individually,
Defendants.
COMPLAINT
COME NOW the Plaintiffs, KENNETH MANFREDI, SR., KENNETH MANFREDI,
JR., and ALEXANDER ... ULTIMATE LOCK SYSTEMS, a Texas
Corporation; RON DANIELS, individually; DARREN BAYSINGER, individually; and
JOSEPH TITONE, individually, and in support thereof allege:
JURISDICTION AND VENUE
1. This is an action ... referred to as the
"BAYSINGER"), is a suijuris Broward County resident.
9. Defendant, JOSEPH TITONE (hereinafter referred to as the "JOSEPH
TITONE"), is a sunfurls Broward County resident.
10. Venue
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198613.pdf
EFTA01198664Set 9
2013-07-1752p11,855w
been furnished
on this 6th day of November, 2013, via electronic mail to Joe Titone, Esq., 621 SE 5 Street,
Pompano Beach, FL 33060, at joetitone708®comeast.net and Steve Mankodi ... ULTIMATE
LOCK SYSTEMS, a Texas Corporation; DARREN
BAYSINGER, individually; RON DANIELS,
individually; and JOSEPH TITONE, individually,
1
Defendants.
AMENDED COMPLAINT
COME NOW the Plaintiffs, KENNETH MANFREDI, SR., KENNETH MANFREDI ... ULTIMATE LOCK SYSTEMS, a Texas
Corporation; RON DANIhLS, individually; DARREN BAYSINGER, individually; and
JOSEPH TITONE, Individttif/bi, and in support thereof allege:
i JURISDICTION AND VENUE
1. This is an action
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198664.pdf
EFTA01128435Set 9
2015-04-3095p18,195w
Okay. Well, you gave a whole long statement
16 to Yager with Titone there.
17 A. Yes.
18 Q. Okay. Now, do you recall when it was that ... come in and I went.
6 Q. Is that when you hired Titone?
7 A. Well, I called him, and he said I should be
8 with ... Bilotti gave you a check
17 for a $1,000 made out to Joe Titone.
18 A. From Mike Bilotti's account?
19 Q. I --
20 A. There
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128435.pdf
EFTA01196860Set 9
2014-05-232p517w
family's been hit with accusations of fraud!
Father-in-law Joe Titone, a lawyer and former Florida state representative, is a target of a lawsuit filed in
Miami-Dade ... part of the
settlement he negotiated.
It's yet another Gossip Extra exclusive:
Titone, the father of Sandler's wife Jackie, was also the subject of a Florida Bar Association ... filed against him and Broward businessman Darren Baysinger.
In a nutshell, Pompano Beach resident Titone, 67, is accused of participating in a scheme to defraud an
investor who died shortly
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196860.pdf
EFTA01092790Set 9
2014-08-1913p3,397w
7Ist Street
Suite 605
V.
Defendant
Harrison Hotel, Inc. represented by Joseph John Titone
621 S.E. 5th Street
Ft. Lauderdale, FL 33060
haps:lied:flsd.uscourts.gov/cgi-bin/DktRpt.pl?72397056246057-L_I_0-1 7/15/2015
EFTA01092790
CM/ECF - Live ... LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Defendant
Michael Kadosh represented by Joseph John Titone
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Date Filed # Docket Text
08/19/2014 ... 9/12/2014. (tm) (Entered: 09/12/2014)
09/15/2014 9 NOTICE of Attorney Appearance by Joseph John Titone on behalf of Harrison
Hotel, Inc., Michael Kadosh. Attorney Joseph John Titone added to party
Harrison
https://www.justice.gov/epstein/files/DataSet%209/EFTA01092790.pdf
EFTA00799428Set 9
2018-04-043p972w
March 29, 2018 by the
attorney for the Plaintiffs, Mr. Joe Titone. It is unfortunate that Mr. Titone appears to be
attempting, again, to engage in ex parte communication with ... respond by way of this letter.
We note as a preliminary matter that Mr. Titone's letter states that you were being
provided with a Motion for Ruling on Service ... clerk on March 29, 2018. In fact, the motion that is
attached to Mr. Titone's letter was Plaintiffs' Motion for Special Set Hearing/Status
Conference.
To give procedural context
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799428.pdf
EFTA00788364Set 9
2017-10-1919p6,183w
Process on Defendant, Jeffrey Epstein without a Hearing. Because the
Plaintiffs attorney, Mr. Titone, is asking by way of his motion that you rule on his motion
without a hearing ... concerned that Mr. Titone may provide his motion to you directly. We
are very much opposed to Mr. Titone's motion and therefore we have filed with the Clerk ... situation.
Very truly yours,
W. CIS BRE JR., ESQUIRE
WCB/msk
Enclosure
cc: Mr. Joseph Titone, Esq.
EFTA00788364
•
Filing # 62990957 E-Filed 10/18/2017 12:26:18 PM
IN THE CIRCUIT COURT
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788364.pdf
EFTA01198718Set 9
2011-04-082p320w
ULTIMATE
LOCK SYSTEMS, a Texas Corporation; DARREN
BAYSINGER, individually; RON DANIELS,
individually; and Joseph Titone, individually,
Defendants.
DEFENDANTS' PRIVILEGE LOG
COME NOW the Defendants Kobaltek, Inc., Darren Baysinger ... Titone, by and through
their undersigned counsel, and file this Privilege Log pursuant to Florida Rule of Civil Procedure
I .280(b)(5):
MATERIALS PROTECTED BY DEFENDANTS' ASSERTION OF ATTORNEY ... INVOICE- April 8, 2011 — Mediation services — From Laurie L. Reimer, Esq. to Joe
Titone — Kobaltek v. DTS
• LETTER - April 8, 2011— Mediation services - From Laurie L. Reimer
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198718.pdf
EFTA00800147Set 9
2017-10-1618p5,835w
S691
December 2, 2016
Via Email: joetitone708@comcastnet
Joe Titone, Esq.
621 S.E. 5th St.
Pompano Beach, FL 33060
Re: Service of Process
Dear Joe,
December 7, 2016
Via Email ... joefitone708acomeast.net
Joe Titone, Esq.
621 S.E. 5ie Street
Pompano Beach , FL 33060
Re: Service of Process
Dear Joe:
I have had an opportunity to review the Notice Service of Process ... email and/or E-file on the 30th day of March, 2017 to Joe Titone,
joetitone708®comcast.net.
W. CHESTER BREWER, JR., P.A.
Counsel for Epstein
250 S. Australian Avenue, Suite
https://www.justice.gov/epstein/files/DataSet%209/EFTA00800147.pdf
EFTA01198720Set 9
2014-06-123p401w
ULTIMATE
LOCK SYSTEMS, a Texas Corporation; DARREN
BAYSINGER, individually; RON DANIELS,
individually; and Joseph Titone, individually,
Defendants.
DEFENDANTS' KOBALTEK, INC. & DARREN BAYSINGER'S RESPONSE TO
PLAINTIFFS' REOUEST FOR PRODUCTION
COMES ... Plaintiffs
already have that document.
8. Objection — any and all documents between Joe Titone and Anthony Titone are
confidential and privileged between the two attorneys.
9. Objection — same ... future.
I I. Objection — same as #10.
12. Objection — same as #10.
/s/ Joe Titone
Joe Titone
Attorney
FL BAR 203882
621 S.E. 5th Street
Pompano Beach, Florida
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198720.pdf
EFTA00801119Set 9
2019-01-034p593w
December
31, 2018. The work billed this month was for settlement discussions with J. Titone. As we agreed,
we performed all of the appellate work (Initial Brief and Reply Brief ... Extension to file Reply Brief; work on same; prepare
email to J. Titone re extension request
12/11/18 DMS As supporting appellate counsel, analyze and 0.40 158.00
scrutinize the most recent ... with J. Epstein on Reply Brief; 0.60 450.00
communications with J. Epstein and J. Titone to
negotiate settlement
12/19/18 SJL Communications with J. Titone re settlement; follow
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801119.pdf
EFTA01198723Set 9
2014-06-122p266w
ULTIMATE
LOCK SYSTEMS, a Texas Corporation; DARREN
BAYSINGER, individually; RON DANIELS,
individually; and Joseph Titone, individually,
Defendants.
DEFENDANT JOSEPII TITONE'S RESPONSE TO PLAINTIFFS' REQUEST FOR
PRODUCTION
COMES NOW Defendants ... Production, and states as follows:
1. Objection — any and all documents requested for Joe Titone, who was the attorney for
Defendant Kobaltek, Inc., are confidential and privileged as attorney-client ... Objection — same
10. Objection — same
I. Objection — same
12. Objection — same
/s/ Joe Titone
Joe Titone
Attorney
FL BAR #: 203882
621 S.E. 56 Street
Pompano Beach, Florida
https://www.justice.gov/epstein/files/DataSet%209/EFTA01198723.pdf
EFTA00804696Set 9
2018-04-042p372w
sent to you on March 29, 2018 by the
attorney for the Plaintiffs, Joe Titone. It is unfortunate that Mr. Titone appears to be
attempting, again, to ex parte ... service of process in this matter.
EFTA00804696
possibility of a settlement and/or
Mr. Titone's letter states that he wishes to discuss the
mediation when there has
mediation ... this matter.
Very truly yours,
W. Chester Brewer, Jr
WCB/slm
Enclosures
cc: Joe Titone, Esquire
EFTA00804697
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804696.pdf
EFTA00648682Set 9
2015-10-214p563w
Jeffrey Epstein <jeevacation@gmail.com>
Sent from my iPad
EFTA00648682
Begin forwarded message:
From: Joe Titone - Attorney
Date: October 20, 2015 at 5:20:27 PM EDT
To: Jack Goldberger c
Subject ... Kadosh gets
dialysis treatments; and sometimes is not available. Tks, JT
Is]
JOE TITONE - ATTORNEY
621 South East 5th Street
Pompano Beach, Florida 33060
Mobile:
Fax:
Primary E-mail:
Seconds ... Subject: MC2 Model Management- Revised Report
Good Afternoon Mr. Titone,
Attached is the revised report.
Should you have any questions, please feel free to contact our office.
EFTA00648683
Thank
https://www.justice.gov/epstein/files/DataSet%209/EFTA00648682.pdf
EFTA00826905Set 9
2016-05-242p390w
From: "jeffrey E." <jeevacation@gmail.com>
To: michel kadosh
Subject: Re: filed by Brad Edwards who titone says you want to meet with
Date ... michel kadosh < > wrote:
Jean luck want titone and your lawyers to do the agreement
Sent from my iPhone
On Feb 3, 2016, at 11:57 AM, jeffrey E. <jeevacation@gmail.com> wrote ... Subject: filed by Brad Edwards who titone says you want to meet with
To: Jean Luc Brunel <j
2Inline image 1
This was filed by Brad Edwards,
please note
EFTA00826905
https://www.justice.gov/epstein/files/DataSet%209/EFTA00826905.pdf
EFTA01206021Set 9
2015-08-142p496w
John Connolly Contributing editor Vanity Fair magazine
To: "Jeffrey Epstein (jeevacation@gmail.com)" <jeevacation@gmail.com>
From: Joe Titone - Attorn
Sent: Thursday, August
To: Jack Goldberger
Subject: Fwd: From: John Connolly Contributing editor Vanity ... Sending it along to you; as a heads up.
I Regards, JT
EFTA01206021
JOE TITONE - ATTORNEY
621 South East 5th Street
Seconds E-mail:
Web:
Sent: Thursday, August ... Subject: From: John Connolly Contributing editor Vanity Fair magazine
Mr. Titone,
Thanks for taking the time to speak with me this afternoon. I am a writer for Vanity Fair magazine
https://www.justice.gov/epstein/files/DataSet%209/EFTA01206021.pdf
EFTA00591494Set 9
6p1,204w
Epstein's Proposal for Settlement to Ma Model & Talent Miami, LLC
Page 3
Joe Titone, Esq., Counsel for Plaintiffs, 621 S.E. 5th Street, Pompano Beach, FL 33061, E-Mail ... period of sixty (60) days to
enforce the terms of the settlement.
JOE TITONE, ESQ. W. CHESTER BREWER, JR., P.A.
Counsel for MC2 Model & Talent Miami, LLC Counsel for Jeffrey ... West Palm Beach, FL 33401
E-Mail: Joetitone708@comcast.net E-Mail: wcblaw@aol.com
By: By:
JOE TITONE, ESQ. W. CHESTER BREWER, JR., ESQ.
Florida Bar No. 203882 Florida Bar No. 261858
Dated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00591494.pdf