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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,
a good faith job hunt in order to receive benefits for lost wages, was not a confidential communication within the ambit of the privilege; see also Watkins v. State, 516 So. 2d 1043 (Fla. 1st DCA 1987), rev. denied, 523 So.2d 579 (Fla. 1988) (defendant's former attorney not barred 13 EFTA00606638 fr
iss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale, Jr., Esq. Florida Bar No.: 115179 Attorney E-Mails: [email protected]; and [email protected]
61)-835-8691 Attorneys for Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale,
9-34791-RBR Doc 6323 Filed 03/19/18 Page 16 of 23 with their lawful orders through civil contempt remedies. Citronelle-Mobile Gathering, Inc. v. Watkins, 943 F.3d 1297. 1301 (11th Cir. 1991). Courts also have the inherent power to sanction a party for misconduct. Chambers v. Nasco, 501 U.S. 32, 42 (1
S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,
VICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail and U.S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbur
tions were intended to be disclosed to third parties or did not involve the giving of legal advice, in which case there is no privilege. See, e.g., Watkins v. State, 516 So. 2d 1043, 1046 (Fla. 1g DCA 1987). VI. THE WORK-PRODUCT PRIVILEGE CANNOT BE DETERMINED FROM EDWARDS' PRIVILEGE LOG 9 EFTA005828
Entities connected to both Jack Scarola and Watkins

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION
Alan Dershowitz
PERSON
Donald Trump
PERSONMarc S. Nurik
PERSON
Weissing
PERSON
Ghislaine Maxwell
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Prince Andrew
PERSON
Scarlett Johansson
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Virginia Giuffre
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Bill Clinton
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United States
LOCATION