Epstein Secrets

ue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08- 80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300

ted Case No. 08- 80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

l Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 10 of 13 Doe 101 v. Epstein Page 10 usually be irrelevant. Cf Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue

hearing indicated that Edwards' burden was proving no probable cause at the time Epstein filed the original civil proceeding and Edwards' counsel, Jack Scarola, corrected him and stated: We contend there was no probable cause to continue the proceeding. The initiation and continuation of the proceeding cau

dary: 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. Edwards

lishing, by the greater weight of the evidence, that Epstein commenced and continued the judicial proceeding against him without probable cause. See Burns v. GCC Beverages, Inc., 502 So. 2d 1217, 1219 (Fla. 1986); Endacott v. Mt? Hospitality, Inc., 910 So. 2d 915, 923 (Fla. 3d DCA 2005) ("plaintiff mu

clients (MI., M. and Jane Doe) of claims they brought against Epstein: 3 EFTA00808635 24 THE COURT: The only thing I would say 25 to that, Mr. Scarola, is I don't want to mix 1 apples and oranges. And that is, I don't 2 want to place the Court's incriminator [sic] on 3 getting too far afield and

y: Primary: Primary: 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-Plainti

vil proceeding against him "without probable cause." See Korman v. Kent, 821 So. 2d 408, 410 (Fla. 4th DCA 2002). Edwards' burden is "onerous." See Burns v. GCC Beverages, Inc., 502 So. 2d 1217, 1219 (Fla. 1986). Edwards' trial strategy is to analyze and test the veracity of each of the individual al

By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0

SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0 not, there is ono agreed matter that we 10 By DAVID P. VITALE JR., ESQUIRE 11 would ask the Court to address first. By KAREN TERRY

Rothstoin's operation of the Point 21 to Frank Burns, 'Frank, you've gone over my 2 scheme. 22 hea

ide for me. And I was pretty mucn ome ess. JACK SCAROLA: One child would be lured over, would be paid sub

parks that were having gun shootings, drugs. My mother was on drugs at the time, and she couldn't provide for me. And I was pretty mucn ome ess. JACK SCAROLA: One child would be lured over, would be paid substantial sums of money, would be offered the further inducement of being paid a bounty for anybody

whose members have included Frank Sinatra, George Burns and Johnny Carson, has served as a bastion for a

parks that were having gun shootings, drugs. My mother was on drugs at the time, and she couldn't provide for me. And I was pretty much homeless. JACK SCAROLA: One child would be lured over, would be paid substantial sums of money, would be offered the further inducement of being paid a bounty for anybody

de for me. And I was pretty much homeless. JACK SCAROLA: One child would be lured over, would be paid sub

whose members have included Frank Sinatra, George Burns and Johnny Carson, has served as a bastion for a

nue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08- 80811 y in jib m Loa ra Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686.6300

543223456 21 Defendant, would not be here. He would not 22 Os Wolf ofOIA: 22 MO plan with ow client. 21 JACR P. IOU. ESQUIRE SEARCY. DENNEY. SCARO1A 23 And immediately n we were approaching the 24 BARNHART* MAZY. PA 2139 Pan lkoch Lain Boulew4 24 deposition room, he made facototace 4500151C

ue, Suite 400 West Palm Beach, FL 33401 Barbara Burns, Esq., State Attorney's Office 401 North Dixie H

224 Datura Street, Suite 900 ch, FL 33401 Jack Scarola, Esq. Jack P. Hill, Esq. Scatty Denney Scarola

aka City, UT 84112 Co-counsel for Plaintiff Jane Doe 08- Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 ch, FL 33401 Jack Scarola, Esq. Jack P. Hill, Esq. Scatty Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for P

774 Case 9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 10 of 13 Doe 101 v. Epstein Page 10 usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue

s, Esq. Richard H. Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth. FL 33461 Fax: Counse for Plaintiff in Related Case No. 08- 80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 C.M.A. Bruce

01 Bs Lau OW Boakard Are 1650 19 20 Pod latillara 3330) 20 21. Tom 21 22 Oa Oshatfolf04A.: 22 23 JACK P. H11/, ESQUIRE SEARCY. DENNEY. SCAROLA. 23 24 BAR/MART& SHIPLEY. P.A. 24 25 2139 Palm Beach Lakes 8Snvd West Palm Beach Fkilda 33409 25 Page 3 1 APPPARNCES CONTINUED_ 1 2 2

ldberger representing Jeffrey Epstein and Barbara Burns representing the State of Florida, and the Court

ue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08- 80811 reelrhwghotmail.com Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300

rd 19 Suiie 1650 20 Pori Liadordok Florida 33301 20 21. Phone 934.m3456 21 22 Om Wulf a 04A: 22 23 /AM P. 3011, ESQUIRE SEARCY. DENNEY. SCAROLA. 23 24 EARMIARTB SHIPLEY. P.A. 24 2139 Pthn Beech Lakes IMievud 25 wen Palm Desch FM& 33409 25 Page 3 1 APPEARNCES CONTINUED-. 1 2 2 3

ldberger representing Jeffrey Epstein and Barbara Burns representing the State of Florida, and the Court