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,

ion on the Epstein files? A. SCAROLA: Same objection and instruction. 201/3-6 201/19-24 201/25 202/4-11 Q. Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? A. SCAROLA: Same objection and instruction. Q. If you're unaware of the existence of the entity

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

e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line

ruling on the issue of probable cause, and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury,

on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA0079

e judged by the facts that existed at the time of the defendant's arrest, not evidence subsequently learned or provided to the prosecution. Madly v. Jenne, 867 So. 2d 1250, 1251 (Fla. 4th DCA 2004) ("Probable cause is judged by the facts and legal state of affairs that existed at the time of the arres

to be heard at oral argument regarding any assertions by Edwards attempting to refute the existence of probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, P

probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

e judged by the facts that existed at the time of the defendant's arrest, not evidence subsequently learned or provided to the prosecution. Madly v. Jenne, 867 So. 2d 1250, 1251 (Fla. 4th DCA 2004) ("Probable cause is judged by the facts and legal state of affairs that 14 EFTA00583965 existed at th

copy of the foregoing has been duly furnished via G Email, G Facsimile, G U.S. Mail, G Hand Delivery, G Federal Express this day of August, 2011: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. P.O. Drawer 3626 West Palm Beach, FL 33409 Jack Alan Goldberger,

Federal Express this day of August, 2011: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley,

team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding their invest

copy of the foregoing has been duly furnished via G Email, G Facsimile, G U.S. Mail, G Hand Delivery, G Federal Express this day of August, 2011: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. P.O. Drawer 3626 West Palm Beach, FL 33409 Jack Alan Goldberger,

Federal Express this day of August, 2011: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley,

team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding their invest

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

e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line

E NO. 502009CA040800XXXXMBAG Amended Complaint Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. Respectfully submitted, Jose

, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, Searcy Denney Scarola et al., 2139 Palm

ein Actions. Those investigators included, but were not limited to Michael Fisten ("Fisten") and Ken Jenne, ("Jenne"), employees of RRA. Fisten and Jenne were the primary investigators assigned to Edwards and to whom they reported to conduct their investigations of Epstein. 15. In October 2009, on o

or the United States Attorney's Office? 13 MR. SCAROLA: Same objection and 14 instruction. 15 BY MR.

A. Not that I remember. 25 Q. Okay. Was, were there any investigators, PROSE COURT REPORTING AGENCY, INC. EFTA00599784 Page 124 1 was Mr. Jenne or Mr. Fisten present? 2 A. No. 3 Q. So, it was, you, Rothstein, Adler, and 4 someone on the phone; that's it? 5 A. From what I remember.

TIFY that a true and correct copy of the foregoing has been furnished by eq Jb U.S. Mail to all counsel on the attached list day of June, 2012. y, JACK SCAROLA Florida Bar No 169440 bss arey Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6

are you? THE WITNESS: Good morning, Tonja. How are you? MS. HADDAD: Fine, thank you. It's nice to see you. THE WITNESS: Good to see you, too. MR. SCAROLA: Mr. Rothstein, ] don't know that you and ] have met. I'm Jack Scarola, I'm representing Brad Edwards and J know you know Brad who's to my immediate

imate things for the law firm, and hiring former Jaw enforcement was the best way to do that. ] was hoping to actually ultimately create a group. Ken Jenne and I had talked about that extensively. Q. Why did you hire Ken Jenne? A. Prior to Ken going to prison, he and ] were Page 32 very friendly and h