Epstein Secrets

s, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff C.M.A. reelrhwahotmail.com 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

l for Plaintiff C.M.A. reelrhwahotmail.com Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarol

sed minimum. As explained by the Landqraf court, supra at 280, and at 1505,2 2 In Landaraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before EFTA00201268 Case 9:08-cv-80811-KAM Document 78

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

e, one of the reasons behind 6(e) is to protect the reputations of persons who arc under investigation but not indicted. This is a corollary to what the Court of Appeals found to be a due process protection afforded by the Fifth Amendment of the United States Constitution — namely, "that the liberty and property con

Unseal. 24 185-15. Copy of a transcript of the Scarola/Edwards 25 interview of April 7, 2011. Unseal i

THE COURT: I will give you a week to file the motion. In the meantime I will still ask counsel to confer and to prepare the papers for release. If the Court of Appeals has not ruled on your motion in a week, then you can let me know. (Court reporter dropped off the call; called back in and read record to the poin

Unseal. 24 185-15. Copy of a transcript of the Scarola/Edwards 25 interview of April 7, 2011. Unseal i

THE COURT: I will give you a week to file the motion. In the meantime I will still ask counsel to confer and to prepare the papers for release. If the Court of Appeals has not ruled on your motion in a week, then you can let me know. (Court reporter dropped off the call; called back in and read record to the poin

ovides that "[t]he district court shall take up and decide any motion asserting a victim's right forthwith." 18 U.S.C. § 3771(dX3) (emphasis added). The Court of Appeals is required to "take up and decide" any mandamus petition for review "within 72 hours after the petition has been filed." Id. (emphasis added). To b

383 S. University St. alt Lake it T 84112 John Scarola Searcy Denney Scarola Barnhart & Shipley 2139 P

the prosecutors are united - or divided. The favor of quick response is — again — requested. cc: Sincerely, 4 Bradle E ards Paul G. Cassell Jack Scarola Counsel for Jane Doe 1, Jane Doe 2, Jane Doe 3, and Jane Doe 4 2 EFTA00027806 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 452-3 Entered