Epstein Secrets

afele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack Scarola, Esq. Karen Terry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL

GENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes

ld not be entitled to enforce the rule under the circumstances of this case. Epstein relies almost exclusively on the Second District's decision in Gawker Media, LLC v. Baal, 170 So.3d 125, 127 (Fla. 2d DCA 2015); which is distinguishable. In Gawker, the plaintiff brought suit against multiple related

rder. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Bu

FY that a true and correct copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Burlin ton & Rockenbach P.A. 350 Co-Coun

is an insufficient remedy. As the Second District explained in Gawker Media, LLC v. Bollea, 170 So. 3d 125 (Fla. 2d DCA 2015): It is true that the Gawker defendants have available to them the legal remedy of pursuing an appeal from any future final judgment, in which they could complain of the erran

93746 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 8'h day of March, 2018: Jack Scarola Sears , Denn , Scarola, Barnhart & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. and i 350 Co-Counsel for Defendant/Counter-Pla

E I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 8'h day of March, 2018: Jack Scarola Sears , Denn , Scarola, Barnhart & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. and i 350 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwar

Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015) ("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440,

0793784 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Motion was furnished via email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, P.A. 350 1 o- ounse or

shed via email this 8th day of March, 2018: Jack Scarola Shipley, P.A. Co-Counsel for Defendant/Counter-

Schoof, 190 So. 3d 169, 170 (Fla. 5th DCA 2016) ("Strict compliance with rule 1.440 is required and failure to adhere to it is reversible error."); Gawker Media, LLC v. Bollea, 170 So. 3d 125, 131 (Fla. 2d DCA 2015) ("[A] party is absolutely entitled to strict conformance with the terms of rule 1.440,

By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0

SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0 not, there is ono agreed matter that we 10 By DAVID P. VITALE JR., ESQUIRE 11 would ask the Court to address first. By KAREN TERRY

OURT: Despite the representation, 29 The law says, in rule 1.440 in the 29 Ms. Rockenbach, that you made in your motion 24 Bennett case and the Gawker case from the 24 to continue, that Plaintiff and his trial 15 Second DCA, says that this Court has to look 25 counsel will not seek another con

ide for me. And I was pretty mucn ome ess. JACK SCAROLA: One child would be lured over, would be paid sub

parks that were having gun shootings, drugs. My mother was on drugs at the time, and she couldn't provide for me. And I was pretty mucn ome ess. JACK SCAROLA: One child would be lured over, would be paid substantial sums of money, would be offered the further inducement of being paid a bounty for anybody

. "We were not in the habit of running away from a fight. But she simply didn't have the goods." Some news organizations, notably the now-shuttered Gawker, did keep plugging away with Epstein stories, even as he receded from headlines at most outlets. Aminda Marques Gonzalez, the Herald's executive ed

parks that were having gun shootings, drugs. My mother was on drugs at the time, and she couldn't provide for me. And I was pretty much homeless. JACK SCAROLA: One child would be lured over, would be paid substantial sums of money, would be offered the further inducement of being paid a bounty for anybody

de for me. And I was pretty much homeless. JACK SCAROLA: One child would be lured over, would be paid sub

. "We were not in the habit of running away from a fight. But she simply didn't have the goods." Some news organizations, notably the now-shuttered Gawker, did keep plugging away with Epstein stories, even as he receded from headlines at most outlets. Aminda Marques Gonzalez, the Herald's executive ed

e E-Mails: ; and Primary E-Mail: Searcy Denney Scarola Bamhart & Shipley, 2139 Palm Beach Lakes Bouleva

XMBAG Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate Set Forth in Rule 1.440 II. Gawker is simply inapplicable here. The Fourth Amended Counterclaim is an independent action filed after Edwards was dismissed from Action #1 (a necessary

: The lawyers who have used the Clinton link to help publicize their cases have been markedly vague on details. When asked to present actual proof, Jack Scarola, the Florida attorney responsible for filing some of the most attention-grabbing documents that have come to light in recent weeks, warned darkly in

kly in an email of “extortionate threats, power, wealth or political pressure.” “The time will come when all your questions will be answered,” said Scarola, who represents another trial attorney suing Epstein in Palm Beach County Court. “But that time is not now.” Unwilling to wait, perhaps, publicatio

ote in April. “Though her LinkedIn page claims a certificate in Swedish massage, there is no evidence that she ever actually treated Epstein to one,” Gawker (in the most straightforward and clearest reporting on the documents to date) wrote last week. And the National Enquirer did not appear to rely on th

: The lawyers who have used the Clinton link to help publicize their cases have been markedly vague on details. When asked to present actual proof, Jack Scarola, the Florida attorney responsible for filing some of the most attention-grabbing documents that have come to light in recent weeks, warned darkly in

kly in an email of “extortionate threats, power, wealth or political pressure.” “The time will come when all your questions will be answered,” said Scarola, who represents another trial attorney suing Epstein in Palm Beach County Court. “But that time is not now.” Unwilling to wait, perhaps, publicatio

ote in April. “Though her LinkedIn page claims a certificate in Swedish massage, there is no evidence that she ever actually treated Epstein to one,” Gawker (in the most straightforward and clearest reporting on the documents to date) wrote last week. And the Nationa/ Enquirer did not appear to rely on th