Epstein Secrets

a true and correct copy of this Response was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff B

te disk containing all the confidential materials..." (Joinder, p. 3). There is no dispute that the documents maintained on a disc transferred from Fowler White are eight years old. There is further no dispute that Edwards and Cassell are fully aware of the documents contained on the disc — they claim the c

ary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 8 EFTA00808693 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley

Order to the Bankruptcy Court's attention. Specifically, on March 19, 2018, Edwards; moved the Bankruptcy Court to issue an order to show cause why Fowler White and Epstein should not be held in contempt of court, to permit discovery, to assess sanctions and costs and for other appropriate relief. (Exhibit

t a true and correct copy of this request was furnished via email this 14th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] [email protected] dvitale

etting out in two affidavits (1) the chain of custody which irrefutably establish that Link & Rockenbach, PA properly obtained the "materials" from Fowler White, Epstein's prior counsel (App. C) and (2) an opinion by ethics expert, Tim Chinaris, who had authored thousands of ethics opinions for over a decad