Epstein Secrets

ndersigned for 25 October at 1:30pm. 2. After receiving notice of this hearing, the undersigned's secretary transmitted an email to Mary, attorney Scarola's secretary. on 11 October asking that they agree to request a reset of that date as the undersigned was already scheduled to leave town for a semin

below, this I8 day of October, 2012. FRED HADDAD, P.A. Tel: Fax• B FRED DAD Florida Bar No. 180891 Page 3 of 4 EFTA00317200 COUNSEL LIST Jack Scarola E . E-mail: Jack Ga ielac E-mail: Marc Nurik, Esa E-mail: Tonja Haddad Coleman. E . - ail: & Lilly Ann Sanchez, Esa. E-mail: nh _ - Page 4

led to 22 October due to the above conflict as well as the fact that the undersigned was already scheduled to appear in West Palm Beach before Judge Colbath on certain felony matters. Further, since this date was convenient as all parties in this matter previously cleared their schedules to appear befor

tlaw.com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

n For Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law [D.E. 65], and the recent ruling from Judge Colbath in the related state court cases, Plaintiffs believe that the issues raised in Defendant's Motion to Stay are moot. Dated: June 29, 2009. -4- Podh

tlaw.com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

t 169 Entered on FLSD Docket 06/22/2009 Page 5 of 8 1. The issuemaybemademoot at a June 25, 2009, hearing before Palm Beach Circuit Court Judge Colbath. 2. This motion is not made for the purpose of delay and should be granted in the interest of equity and fairness. WHEREFORE, Plaintiffs, Jane Do

to answer q~estions, As he did in the civil. lawsuits, Epstein has :invoked his Fifth Amendment right against self-incrimination when que~tfoned by Scarola-. Edwards ha:s claimed that much of the infc;>Jmati_on Epstein is se:eking is J)'rotected by attorney-client privilege. The n;ialicioµs prosec::µti

" other young women ,against Epstein, claiming he paid them for sex "f• .•. ·-· ,,_ • .. ,. _.J} when some were as young as l4 years old. Attorney Jack Scarola, who is representing Edw2,rds1 said his client was c.orn:pelled to divulge the confidential settlements to answer q~estions posed by'Epstein's-attor

uments unsealed/’wrote former CircuitJudge Bill Berger, now in private practice arid representing one of the women. The Palm Beach Post also will ask Colbath to unseal the agreement., Post attorney Deanna Shullmari will argue that the public has a right to know the specifics of Epstein’s deal-.. According

hly two dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex when some were as young as 14 years old. Attorney Jack Scarola, who is representing Edwards, said his client was compelled to divulge the confidential settlements to answer questions posed by Epstein's attorneys

ents to answer questions posed by Epstein's attorneys. "Brilliant move on their part," he said. Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have likely come out. He says the information will help him undermine Epstein's claims that Edwards "ginned up" the alle

ts unsealed," wrote former Circuit Judge Bill Berger, now in private practice and representing one of the women. The Palm Beach Post also will ask Colbath to unseal the agreement. Post attorney Deanna Shullman will argue that the public has a right to know the specifics of Epstein's deal. According t

tlaw.com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

9, hearing before Palm Beach Circuit Court Judge Colbath. 2. This motion is not made for the purpose of

COUNTY, FLORIDA 2 Videotaped Depoeitien ofWILLIAMBERGER Page lb. Case No. 502009CA040800XXXXMB 4 JEFFREY EPSTEIN, 5 Direct Examination by Hr. Scarola 5 Plaintiff/Counter-Defendant, 4 Cross-Lamination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individuall

16 MR. LINK: Sure. Scott Link on behalf 26 2139 Palm Beach Lakes Boulevard 17 of plaintiff, Jeffrey Epstein. West Palm Beach, FL 33409 27 By JACK SCAROLA, ESQUIRE 19 MR. INDYKE: Darren Indyke on behalf of la 19 plaintiff, Jeffrey Epstein. 19 ALSO PRESENT 20 MR. SCAROLA: My name is Jack Scarola

o that. 1 4 S 7 agreement unsealed. That's something I spent a lot of time on. I attended, I believe, at leant two hearings In front of Judge Colbath -- • To get that unsealed? A -- to get that unsealed. • What wan the purpose in getting that • unsealed? • A So that it could be used as e

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

l Circuit-Palm Beach Palm Beach County Courthouse Main Judicial Complex 205 N. Dixie Highway, Room 11F West Palm Beach, FL 33401 Re: Dear Judge Colbath: Tampa 40D N. Maley Dr., Ste. 1100. Tampa. FL 33002 P.O. Box 2002. Tempe. FL 33801-2602 FP 813 90 3080 fax 813-984-3070 toll five 888-395.7100 F

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

tr Now York Clly 220 E. 42nd Sc. 10th Floor www.Oclawliny eme De Direct Dial:NOB Deanna.Shullmanf000lawerm.com Reply To Tampa Re: Dear Judge Colbath: Enclosed is a courtesy copy of non-party Palm Beach Newspapers, Inc. d/b/a The Palm Beach Post's (the "Post") Motion to Intervene and Petition for

Court by using CM/ECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. istlank P Hill Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm 6409 P

the attached service list. istlank P Hill Jack Scarola Florida Bar No.: Jack P. Hill Florida Bar No.:

l Circuit-Palm Beach Palm Beach County Courthouse Main Judicial Complex 205 N. Dixie Highway, Room 11F West Palm Beach, FL 33401 Re: Dear Judge Colbath: Tampa 400 N. Nib* Dr., Ste. 1100, Tampa, FL 38602 P.O. Sox 2602, Tam D2 0.813-sefseso b iota Ft. Lauderdale 101 N.E. 710r0 Ave., Ste. 1500