Epstein Secrets

s Blvd., Suite 301 West Palm Beach, Florida 33401 T 561.727.3600 F 561.727.3601 Scott J. Link CONFIDENTIAL SETTLEMENT COMMUNICATION VIA E-MAIL Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 November 15, 2017 VIA E-MAIL Bradley J.

Beach, Florida 33401 T 561.727.3600 F 561.727.3601 Scott J. Link CONFIDENTIAL SETTLEMENT COMMUNICATION VIA E-MAIL Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 November 15, 2017 VIA E-MAIL Bradley J. Edwards Edwards Pottinge

result in Brad having to file personal bankruptcy. In light of the testimony given by Brad at his recent deposition, the speculative nature of Dr. Jansen's expert report, and the exorbitant amount Brad is seeking, our client has reevaluated his position and has now authorized us to offer Brad a "walk

age Furthermore, Edwards has testified that he has "resurrected" any damage that was done to his reputation: On August 17, 2012, Edwards' counsel, Jack Scarola, made a public statement to the media which he believes was "successful in discrediting Mr. Epstein's charges." (Jansen's 12/1/17 Tr. 62.) (Ex. E.)

No. 10 Q. Did you do any research into whether the 11 impact on the readership in forming an opinion about 12 Mr. Edwards was different after Mr. Scarola made his 13 statements in 2012 to the press? 14 A. No. 15 Q. When you did your research did you interview 16 any readers that actually read one o

would be reversible error. Edwards' Expert is a Defamation Expert. Not a Malicious Prosecution Expert The error is compounded by the fact that Dr. Jansen's testimony is focused on defamation per se, without regard to the actual damages proximately caused by the malicious prosecution (if any). Edwards

ary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 7 EFTA00805481 SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plain

Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 7 EFTA00805481 SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards

dwards' 11/10/17 Tr. 22:5-17.) To the contrary, however, Edwards' counsel has stated that he was successful in discrediting Epstein's allegations. (Jansen's 12/1/17 Tr. 62:24-25.)2 In addition, Edwards himself testified that his reputation has been "resurrected" and is "better than it has been": "With

u CtOpare the S By SCOTT J. LINK, ESQUIRE 6 For Defendant/Counter-Plaintiff: 4 exhibit lists of Novenber 16th and Densber 22nd, SEARCY, DENNEY, SCAROLA, BARNHART 4 7 which, as I said, are the same, with the March 5th 7 SHIPLEY, P.A. 8 exhibit list, 25 new exhibits -- excuse me -- 724 8 9 new

I said, are the same, with the March 5th 7 SHIPLEY, P.A. 8 exhibit list, 25 new exhibits -- excuse me -- 724 8 9 new exhibits were added. By JACK SCAROLA, ESQUIRE 10 Your Honor held a hearing in this matter on 9 By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE II Deoksbor 5th and nide it

. I don't 2 KR. BURLIAVTON: Your Honor, it's his action. 3 think there's another set of files somewhere. 3 KR. SCAMLA: The notion to ➢trite Dr. Jansen. 4 Fowler White had asked me to return them once we 4 THE COURT: All right. 5 went through them, and if the Court can instruct me s MR. BURLIA

NBACH, ESQUIRE 5 new exhibit list was filed. If you compare the S By SCOTT J. LINK, ESQUIRE 6 For Defendant/Counter-Plaintiff: SEARCY, DENNEY, SCAROLA, BARNHART C 4 7 exhibit lists of Hovenber 16th and Densber 22nd, which, as I said, are the same, with the March 5th 7 SHIPLEY, P.A. 8 exhibit

I said, are the same, with the March 5th 7 SHIPLEY, P.A. 8 exhibit list, 25 new exhibits -- excuse me -- 724 0 9 new exhibits were added. By JACK SCAROLA, ESQUIRE JO Your Honor held a hearing in this matter on 9 By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE 11 Deowbor 5th and mud it cl

. I don't 2 KR. BURLIAVTON: Your Honor, it's his action. 3 think there's another set of files somewhere. 3 KR. SCAMLA: The notion to ➢trite Dr. Jansen. 4 Fowler White had asked me to return them once we 4 THE COURT: All right. 5 went through them, and if the Court can instruct me s MR. BURLIA

igital or electronic format), and all amendments, modifications and supplements thereto, memorializing, any and all arrangements that Paul Cassell, Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or Boies Schiller Flexner LLP have or at any time during the period in question had with any and all

any and all arrangements that Paul Cassell, Jack Scarola, Searcy Denney Scarola Barnhart & Shipley PA, or

dwards instructed Epstein: Please confirm receipt of the materials provided by Dropbox, and further confirm that these materials, together with Dr. Jansen's report and the information disclosed last week regarding Dr. Jansen, satisfy the expert witness discovery you recently propounded. If there is a

counsel before noticing hearing by review of J. Scarola's proposed Pre-Trial Stipulation and last version

2,745.00 225.00/hr EFTA00804041 11/21/2017 TLC Jeffrey Epstein Page 5 Hrs/Rate Amount Notice of Deposition and Subpoena Duces Tecum for Dr. Jansen; follow up with J. Scarola re same; work on trial notebooks 11/14/2017 KBR Work on response to B. Edwards' Request for Judicial Notice; work 6.50

ve been retained by the law firm of Searcy Denney Scarola Barnhart & Shipley, PA. to provide expert analys

2016 President's Award for Engagement with Students, The Pennsylvania State University, University Park, Pennsylvania. 2015 Best Paper: Liu, Z. and Jansen, B.J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Comp

B [t S 03/22/18 RJG R D fc • 03/22/18 RJG C c; 03/22/18 RJG C h. Inspection; work on it of Certiorari; work on Ause in Bankruptcy . Scarola and D. Vitale .c -Ind changes to •?ction to Unilaterally as with J. lanno re hearing attendance; yke Ile and J. Scarola re ;19 style of case;

rgue at all-day special set hearing on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, Edwards' Motion to Strike Exhibits, and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files; follow up with