Epstein Secrets

, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 JSX@searc

dwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 [email protected] BY: WILLIAM B. KING, ESQUIRE 22 [email protected] 23 24 25 www.phippsreporting.com 888 811-3408 EFTA00606511

are not subject to the litigation www.phippsreporting.com 888 811-3408 EFTA00606536 23 1 2 3 4 5 6 privilege. And if you read Wright vs. Yurko, you read Judge Cope's concurring opinion, and you read the panel's footnote in SCI, one should not come up with any other conclusion other than t

ion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 recognizes -- that is the Supreme Court itself 2

nt. I HEREBY CERTIFY that a true copy of the foregoing was furnished to all counsel on the attached service list, by email, on September 25, 2017. Jack Scarola, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 WM, BURLINGTON & ROCKENBACH, P.A. C

, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 JSX@searc

ims are not subject to the litigation www.phippsreporting.com 888 811-3408 001237 EFTA00613534 28 1 privilege. 2 And if you read Wright vs. Yurko, you read 3 Judge Cope's concurring opinion, and you read the 4 panel's footnote in SCI, one should not come up 5 with any other conclusion oth

ion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 24 25 recognizes -- that is the Supreme Court i

ris SERVICE LIST: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. Philip M. Burlington

ts known by the defendant in the malicious prosecution action at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present

at the time the underlying action was initiated, not some later point in time."). In Yurko, the Fifth District concluded: "The affidavit here shows Yurko reasonably researched and investigated his case, and had a tenable theory to present to the court and jury." 446 So. 2d at 1167. Here, both the aff

afele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack Scarola, Esq. Karen Terry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL

ott J. Link FBN 602991 Primary: Secondary: 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

n determine whether Plaintiff "had a reasonable belief, based on facts and circumstances known to him, in the validity of his claim." See Wright v. Yurko, 446 So. 2d 1162, 1166 (Fla. 5th DCA 1984) (defining probable cause) (citing Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956)). Bifurcating the tria

a state and federal courts. See, SCI Funeral Svs. of Fla., Inc. v. Henry, 839 So. 2d 702, n.4 (Fla. 3d DCA 2002) (“As the Levin court cited Wright v. Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA, 1984), with approval, presumably the cause of action for malicious prosecution continues to exist and would not

I HEREBY CERTIFY that on November U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK -

ber U , 2010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list. Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK --- SERVICE LIST Christo