Epstein Secrets

al Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST 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 J.

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J.

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Reach. FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J.

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel Jro DeJendan&Counter-Plaintiff Bradley J. E

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

ndary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST 5 EFTA00808730 Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, •. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J.

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter

Y CERTIFY that a true and correct 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

nday, March 5, 2018, Epstein filed his to motion to remove the case from trial docket in order to comply with the mandate of Rule 1.440 and opposed Edwards' Motion for Pursuant to the clear language of the rule, if the action involves a main claim or counterclaim which has neither been answered nor defaulted,