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

ial set 10-day trial commencing on December 5, 2017, and to extend the pre-trial deadlines. In the alternative, Plaintiff moves under Rule 1.270 of the Florida Rules of Civil Procedure to bifurcate the trial and limit the first stage of the proceedings to: (i) Plaintiff's case and damages against Defendant Scott Rothstein and (ii)

urnished by Fad and U.S. Mail to all Counsel on the attached list of October, 011. ce..tcge a ar No.: 169440 Denney Scarola Barnhart & Shipley Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards 2 EFTA00600161 10/26/2611 15:00 FA

0800)OOCXMBAG REOUEST TO PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, requests, pursuant to Rule 1.3 0 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. NI/ Ed ards to inspect and copy each of the following documents*: 1. All contracts for legal s

ished by Electronic and U.S. Mail to all Counsel on the attached list, this 2012. Jack a Flo ar No.: 169440 Denney Scarola Barnhart & Shipley Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone: Fax: Attorneys or Bradey7 dwwards 2 EFTA00613616 COUNSEL LIST Bradley J. Edwards, Esquire Farmer, Jaf

Defendant(s). REQUEST ro PRODUCE TO JEFFREY EPSTEIN Bradley J. Edwards by and through his undersigned counsel, request, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1. Paragraph 12 of Edwards' Thi

ished by Fax and U.S. Mail to all Counsel on the attached list, th 110.1)—day of la `• Bar No.: 169440 cy Denney Scarola Barnhart & Shipley 139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for 2010. 3 EFTA00722341 09/16/2010 14:45 FAX SEARCY DENNEY in004/004 Edwards ' adv

ENDANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel, recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1.

was sent via E-Serve on this ( day of Oh l- , 2015. Jack S Flori An m P "mary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Plaintiff 3 EFTA00597518

ent this proposal is rejected, the Defendant is subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

oing was sent via E-Serve to all Counsel on the attached list, this JACK Florid Atto me P ary Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Plaintiffs day of 2015. EFTA00597514 Edwards/Cassell

ent this proposal is rejected, the Defendant is subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

Att. E-Mail(s): [email protected] and ,searcylaw.com ary E-Mail: [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Plaintiffs EFTA00602649 Edwards, Bradley vs. Dershowit

uments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

sel on the attached list, this ti day of JAC OLA PI ar No.: 169440 P E-mail: .ndary E-mail(s): Searcy Denney Sterols ar l IWARIP.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Bradley J. Edwards 20 (1/ EFTA00788618 Edwards adv. Ep

cuments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

/ JAC OLA Fl ar No.: 169440 P E-mail: [email protected] i .ndary E-mail(s): [email protected] Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorney for Bradley J. Edwards EFTA00598927 Edwards adv. Epstein C

cuments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

wards, Bradley adv. Epstein (File #: 291874) Mary Pirrotta Secretary to Jack Scarola, Esquire Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone Fax: Email: Privileged and Confidential Electronic communication is not a secure mode of communication and may b

i, 10 Aug 2012 13:27:39 +0000 Mr. Scarola: Your letter and "supplemental response to discovery" are neither permissible nor acceptable pursuant to the Florida Rules of Civil Procedure. The fact that your client purportedly produced these documents in another case in which my client was not even a party is irrelevant and, indeed, n