Epstein Secrets

ary: Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach FL 33409 ter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 Wes

nbach, P.A. Please direct all pleadings, discovery and orders in this matter to the following counsel: Scott J. Link Link & Rockenbach, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach. Florida 33401 Telephone: Facsimile: Primary: Secondary: A18 EFTA00798184 CERTIFICATE OF SERVICE I certify that

tion. A21 EFTA00798187 Court of Appeal reversed and remanded in November 2015, with the Mandate issuing in December 2015. The matter was sent to the Florida Supreme Court and, in large part, there were no substantive filings in this case until June 2017, after the Supreme Court declined jurisdiction. Defendant notice

t the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. EFTA00788219 109 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: For Bradley Edwards: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE, JR. For Bradley Edwards: BURLINGTON & ROCKENBACH PA 444 W Railroad Avenu

12 13 14 15 16 17 18 19 20 21 22 23 24 25 -- the case had basically not been actively prosecuted in this court until June 2017 when the Florida Supreme Court issued its final ruling. So should the Court grant our motion, we did preserve the right to redepose Mr. Edwards on these issues. We feel not onl

d via email this 19th day of March, 2018: 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 I Edwards Philip M. Burlington Nichole J. Segal Burlington & Rocke

TA00808483 case was remanded to the trial court after being up before the Fourth District Court of Appeal for one and a half years and waiting for the Florida Supreme Court to rule for another year and a half. (App. 10.) The Order setting trial resulting from that Motion was not entered until July 20, 2017. (App. 11.)

served by mail vA this Cl day of February, 2011 on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley Attorneys for Bradley J. Edwards 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Marc S. Nurik, Law Offices of Marc S. Nurik Attorneys for Scott Rothstein One E. Broward Blvd., Ste 700 Fort Lauderda

ranscript at 50, 54, 91, 100-104, 114, 126,-127, 155, 170, 181, 184-187, 192, 198-202, 205-206, 208-210, 212, 215-217; Exhibit 1. Forty years ago, the Florida Supreme Court, in Surf Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), gave this general definition of work product saying what it is and what it is no

aw Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. - 5 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH

Fla. 1996) (citing Dodson v. Pend!, 390 So. 2d 704 (Fla. 1980); Suif Drugs, Inc. v. Vermette, 236 So. 2d 108 (Fla. 1970)). -"S ,r‘ II. In Elkins, the Florida Supreme Court commented on the purpose of pretrial discovery: Discovery was never intended to be used as a tactical tool to harass an adversary in a manner that

fore the Grand Jury of the United States District Court at the place, date and time specified below. PLACE: Fourth District Court of Appeals 1525 Palm Beach Lakes Boulevard West Palm Beach, Florida 33401 (Temporary location for the United States District Courthouse, West Palm Beach) ROOM: Courtroom DATE AND TIME: O

nts is without a basis in Florida law. We find no evidence that the Florida courts derive an evidentiary privilege from Fla.Stat. 905.27. Indeed, the Florida Supreme Court has noted that Mlle rule of secrecy concerning matters transpiring in the grand jury room is not designed for the protection of witnesses bef