Epstein Secrets

March 23, 2010, counsel to Epstein deposed Edwards. During that examination, Edwards refused to answer numerous questions to which he or his counsel Jack Scarola objected. For example, he was asked generically about RRA's document storage system: Q. And what type of information did you put into Q-task regard

gh Edwards could have answered the question without disclosing information intended to be kept confidential by his client L.M3 Id. at 99. 10. Mr. Scarola also erroneously counseled Edwards not to answer a series of question about his communications with federal prosecutors: ". . .do you know whether,

EFTA00606629 1.) For example, Edwards's attorney instructed him when Edwards was asked how one plaintiff, E.W., came to contact referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that

referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. a

ions on page 228 lines 1 though 13, Edwards admits that he received written and oral reports from investigators — before he answers though, he asks Scarola if he should answer and Scarola says "yeah." Id. at 229. The discussion turns to the manner in which the cases were handled while Edwards was a pa

Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799426 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

ions on page 228 lines 1 though 13, Edwards admits that he received written and oral reports from investigators — before he answers though, he asks Scarola if he should answer and Scarola says "yeah." Id. at 229. The discussion turns to the manner in which the cases were handled while Edwards was a pa

neys for Epstein 25 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585418 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

Plaintiff: 14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 15 Cambridge, Massachusetts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART & SHIPLEY, P.A. 20 West Palm Beach, F on a Phone: 21 22 ALSO PRESENT: 23 Jeffrey Epstein

UIRE HARVARD LAW SCHOOL 15 Cambridge, Massachusetts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART & SHIPLEY, P.A. 20 West Palm Beach, F on a Phone: 21 22 ALSO PRESENT: 23 Jeffrey Epstein 24 Joseph Kozak, Videographer Pr

RA, if those cases had resolved 11 during that time period, RRA, you would have paid 12 RRA that portion to which you were been entitled and 13 Howell and a Cassell would have gotten their 14 percentage? 15 A. Correct. 16 Q. And with regard to, with the new firm, the 17 Farmer, Jaffe firm,

ose cases there was a, 13 there is also another lawyer that was involved -- 14 well, let me strike that. In one or more of those 15 cases is Mr. Howell involved, or was he at the time 16 you were a solo practitioner? 17 A. What do you mean by involved? 18 Q. Involved, was he a referring lawye

5467 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Response was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409

rect copy of this Response was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards

t the Palm Beach County Bench Bar Conference likely delayed Edwards' efforts at submitting an order. 6 EFTA00805463 For Mr. Cassell, through Mr. Howell, to suggest anything contrary to Epstein's counsel's complete cooperation and compliance with the trial court's rulings is unfounded, scandalous, i