Epstein Secrets

he Court by using CWECF system, which will send a notice of electronic filing to all counsel of record on the attached service list. Atlank P Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Phone: Fax. Attorneys for Plaintiff 4 EFTA00722684 Case 9:08-cv-80811-KAM Do

n the attached service list. Atlank P Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida B

. It is the rule, rather than the exception that civil and criminal cases proceed together." United States ex reL Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here.

FY that on September A 2010 a copy of the foregoing has been served via U.S. Mail and email transmittal to all those on the attached service list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P

to all those on the attached service list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm

ed more severely than a first offender . . . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. v. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail this day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury Gol

l and U.S. Mail this day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley,

and 3) damage as a result of the conduct. See, e.g., S&I Invs. v. Payless Flea Mkt., 36 So. 3d 909, 917 (Fla. 4th DCA. 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n. 2 (Fla. 3d DCA 2006); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). With regard to the

Case 9:08-cv-80736-KAM Document 56 Entered on FLSD Docket 04/07/2011 Page 9 of 19 I and Jane Doe 2. Ile and his own lawyer in a related state case, Jack Scarola, have been widely quoted by local and British press, making prejudicial and inflammatory statements about Mr. Epstein. If the correspondence betwee

nd inflammatory statements about Mr. Epstein. If the correspondence between the defense team and the government is not kept confidential, attorneys Scarola and Edwards could reasonably be expected to continue disseminating out-of-court publicity and making extrajudicial statements and commentary to the

ight to approve or disapprove a proposed plea in advance or to participate in plea negotiations." In re Dean on remand as United States tBP Products North America, Inc., 610 F. Supp. 2d 655, 727 (S.D. Tex. 2009). Instead, "[t]he purpose of the reasonable right to confer is for victims to provide information t