Epstein Secrets

ponse 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 Bradley I Edwards Philip M. Burlingto

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

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

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

Petition was furnished via email this day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley J. Edwards Philip M. Burlington

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

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

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

rrect copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Burlin ton & Rockenbach P.A. 350 Co-Counsel for Defendant/Cou

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

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

quest 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] [email protected] scarolateam@searcylaw

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

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

IFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Motion was furnished via email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, P.A. 350 1 o- ounse or ee ant Co

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

DATED this day of , 20 . Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Phone: Fax: Attorneys for Plaintiff(s) Shipley, P.A. EFTA00722714 v, Epstein, et al Case No. 50 2008CA025129=O(MB Al SDT Without Deposition Page3 CERTIFICATION OF RESPONSE TO SUBPOENA DUCE

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to

2 Fort Lauderdale, FL 33301 954-524-2820 954-524-2822 - fax Attorneys for Defendant, LM. Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 686-6300 383-9424 F Attorneys for Defendant Bradley Edwards Jack Alan Goldberger, Es

e time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00724400 "What the evidence is really going to show is that Mr. Epstein — at least

hed list, this V day of February, 2009. Jack Scarola Florida Bar No.: 189440 Jack P. Hill Florida Bar No.: 0547808 Attorneys for Plaintiff(s) Shipley, P.A. EFTA00614441 A.C. v. Epstein, et al Case No. 50 2008CA025129XXXXMB Al Notice of Production from Non-Party Page 3 COUNSEL LIST sissi At

0 minutes Hearing on Defendant Epstein's Motion to Dismiss, for More Definite Statement, and to Strike Directed to Plaintiffs Complaint Dear Judge Hafele: Enclosed please find a copy of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, and to