Epstein Secrets

JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 and BURLINGTON & ROCICENBACH, P.A. 444 West Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Attorneys for Res o

f the cases were to be tried together (App.19, p.266) Thus, the trial court denied Epstein's motion to remove the case from the docket and granted Edwards's Motion to sever the two cases for trial (App.18, p.184; App.19, pp.265-67). The court held that it would try Edwards v. Epstein as scheduled on March 13,

l parties listed below, via Electronic Service, this April 28, 2013. Electronic Service List Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33

either good cause or any law in support thereof, fails to satisfy the heightened requisite showing for an order of protection, mandating denial of Edwards's Motion. Third, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privac

to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL

Ponzi Scheme was becoming urgent. Depositions taken of Scott W. Rothstein in In re: Rothstein Rosenfeld: Adler, PA; 09-34791-RBR. The court rejected Edwards's Motion, calling it "devoid of evidence." See Order in Jane Doe No. 2 v. Epstein Dated November 5, 2009, 08-cv-80119. The connection between many of these

1223 954.337.3716 facsimile EFTA00582842 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . • Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL

as "government privilege," notwithstanding that it is he who is prosecuting this matter and who bears the burden of proof. As such, not only should Edwards's Motion to preclude evidence be denied, but Edwards should also be precluded from presenting any evidence or testimony for which he has asserted any privil