Epstein Secrets

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

I HEREBY CERTIFY that 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

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

ICE I HEREBY CERTIFY that a true and correct copy of this 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-

stein never even knew Fowler White had the disc until we found it." Counsel for three victims — identified as L.M., E.W. and Jane Doe — asked Judge Hafele to order Fowler White to explain its handling of the confidential documents, but he said he lacked the authority to do so since the firm had withdr

d the materials from Fowler White's files. According to the motion, during a March 8 hearing on the privileged communications, State Circuit Judge Donald W. Hafele said, "The critical question, though, is why did Fowler White have these documents, why were they continued to be held, and was it in violation eith

k and Kara Rockenbach of Link & Rockenback PA and Jack A. Goldberger of Atterbury Goldberger & Weiss PA. Edwards is represented by Jack Scarola and David P. Vitale of Seamy Denney Scarola Barnhart & Shipley PA and Phil Burlington and Nichole J. Segal of Burlington & Rockenbach PA. L.M., E.W. and Jane Doc arc r

, over more than six years, to seek a default against Rothstein[.]" (Resp. at p. 1) [emphasis added]. However, at the March 8, 2018, hearing, Judge Hafele held Edwards equally responsible for the current Rule 1.440 issue because Edwards was the party who 2 EFTA00808473 noticed the case for trial an

in Jack A. Goldberger Atterbury, Goldberger & Weiss, 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 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 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Eps

CE I HEREBY CERTIFY that a true and correct copy of this Reply was furnished 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-

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

I HEREBY CERTIFY that 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] jsx@searcylaw

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

else did he tell you? MR. LINK: So, I'm going to instruct you not to answer based both on attorney- client privilege and exceeds the scope of Judge Hafele's order. I" Epstein Depo. Tr. at 22. Clearly Epstein put forward the conversation with his attorney about the disc in paragraph four of his declara

derson FLBN 118247 Edwards Pottinger LLC Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jack Scarola, Esi= Florida Bar No. David P. Vitale, Florida Bar No. Attorney E-Mails' Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. Attorneys for Bradley J. Edwards Scott J. Link

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

0 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale, Jr., Esq. Florida Bar No.: 115179 Attorney E-Mails: [email protected]; and [email protected] Primary E-Mail: [email protected] Sear

Jack A. Goldberger Atterbury, Goldberger & Weiss, . 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 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 Co-Counsel for Plaintiff/Counter- Defendant Jed E , st

that a true and correct copy of this request was furnished via email this 19th day of March, 2018, to the following: 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-

T (Adds Item No. 22) PLEASE TAKE NOTICE that this case is currently set on the Court's trial docket for August 2 and 3, 2018, before The Honorable Donald W. Hafele, Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida, Courtroom 10D, on the following matters: No. Motion/Request Dat

991) Kara Berard Rockenbach (FBN 44903) Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. ounse Bradley J. Edwards laintiff Philip M. Burlington Nichole J. Segal Burlington & Roc

hich duplicates the disc we located in Fowler White's files. We have retained our copy and will bring a copy of the disc to Court tomorrow for Judge Hafele. There are approximately 22,000 pages that we have yet to review. Please let me know if you agree to the appointment of a Special Master to review

please do not to to contact me. Si Scott J. Link SJL/tic Enclosure cc: Paul Cassell (via e-mail, w/o enc.) Jay Howell (via e-mail, w/o enc.) David P. Vitale, Jr. (via e-mail, w/o enc.) Bradley J. Edwards (via e-mail, w/o enc.) Nichole J. Segal (via e-mail, w/o enc.) Jack A. Goldberger (via e-mail, w/o