Epstein Secrets

mail.com 561-832-7732 _________ 561-832-7137 F Jack Scarola, Esq. • [email protected] Jack P. Hill

com 561-832-7732 _________ 561-832-7137 F Jack Scarola, Esq. • [email protected] Jack P. Hill

, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405] The Honorable Herbert Stettin ("Stettin"), the State Court appointed1 receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

Willits, P.A. 2290 10th Avenue North Suite 404 Lake Worth, FL 33461 F 0A. ..JV I ,IVLI TJV I Counsel for Plaintif in Related Case No. 08-80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarole Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel f

for Plaintif in Related Case No. 08-80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarol

, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405) The Honorable Herbert Stettin ("Stettin"), the State Court appointed' receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

24 25 Page 5 this case, who is the one who would be asserting the privilege. Mr. Edwards, as I understand it, is representing himself. Actually, Jack Scarola is his attorney. I've had a chance to review the documents. I've printed them out and reviewed them. Just to place things in its context, the sta

tand it, is representing himself. Actually, Jack Scarola is his attorney. I've had a chance to review th

sert the privilege. And I'm seeing legally some appellate issues with that one. Actually, I think we may end up being in a reversible situation in the State Court on that, if it goes before Appellate Court scrutiny. So I'm concerned at this point legally telling Mr. Edwards and telling Mr. Farmer that they

ue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 reelrhwahotmail.com Jack Scarola, Esq. Jack P. Hill, Esq. Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-63

ted Case No. 08-80811 reelrhwahotmail.com Jack Scarola, Esq. Jack P. Hill, Esq. Seamy Denney Scarola

, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405) The Honorable Herbert Stettin ("Stettin"), the State Court appointed' receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

tein. COURT: After he found it. SCAROLA: Well, he obviously couldn't transfer it before. COURT: But that's what you're litigating in state court. SCAROLA: No, sir, I'm sorry, that's not what we're litigating in state court. What we are litigating in state court is the malicious prosecution claim. Wha

e 8 of 97 LINK c R KENBA H PA By: /s/ Scott J. Link SCOTT J. LINK (FBN 602991) [email protected] Counsel for Jeffrey Epstein SERVICE LIST Jack Scarola ar D nn ar la Barnhart & Shipley, P.A. Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC °tense o

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Movants contend that Epstein's

tein. COURT: After he found it. SCAROLA: Well, he obviously couldn't transfer it before. COURT: But that's what you're litigating in state court. SCAROLA: No, sir, I'm sorry, that's not what we're litigating in state court. What we are litigating in state court is the malicious prosecution claim. Wha

l Rule 2090-1(A). LINK & ROCKENBACH, PA 930 By: Is/ Scott J. Link SCOTT J. LINK (FB Counsel for Jeffrey Epstein 7 EFTA00794244 SERVICE LIST Jack Scarola ar D nn ar la Barnhart & Shipley, P.A. rd Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC ouns

o answer those questions is of no moment. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. 5 EFTA00794242 CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Edwards cont

tein. COURT: After he found it. SCAROLA: Well, he obviously couldn't transfer it before. COURT: But that's what you're litigating in state court. SCAROLA: No, sir, I'm sorry, that's not what we're litigating in state court. What we are litigating in state court is the malicious prosecution claim. Wha

(FBN Counsel for Jeffrey Epstein SERVICE LIST Jack Scarola & Shipley, P.A. ounse or ra ey wars Bradley J

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Edwards contends that Epstein'

ida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). Is/ David P. Vitale Jr. Jack Scarola Florida Bar No.: 169440 David P. Vitale Jr. Florida Bar No.: 115179 Attorney E-Mails: [email protected]; and [email protected] Primary E-Ma

al Rule 2090-1(A). Is/ David P. Vitale Jr. Jack Scarola Florida Bar No.: 169440 David P. Vitale Jr. Fl

ed the adequacy of Mr. Edwards's privilege log years ago. 6 EFTA00795932 Case 09-34791-RBR Doc 6358 Filed 04/12/18 Page 7 of 12 At one point, the State Court—the only Court with jurisdiction over the adequacy of the log— agreed that the log was insufficient and then before requiring a revised log reversed

da Bar No.: 132896 FARMER, JAFFE, WEISSING, EDWARD FIT LEHRMAN P.L. 16 EFTA00708308 Case 09-34791-RBR Doc 1603 Filed 0410811 Page 17 of 23 Jack Scarola Florida Bar No.: 169440 Searcy, Denney, Scarola, Barnhart & Shipley Attorney for Bradley J. Edwards in the matter of Epstein v. Edwards, et at Ca

T LEHRMAN P.L. 16 EFTA00708308 Case 09-34791-RBR Doc 1603 Filed 0410811 Page 17 of 23 Jack Scarola Florida Bar No.: 169440 Searcy, Denney, Scarola, Barnhart & Shipley Attorney for Bradley J. Edwards in the matter of Epstein v. Edwards, et at Case No.: 502009C40408000CCaMBAG 17 EFTA00708309

relevance, burdensomeness, and attorney-client and other privileges regarding the Razorback Creditors' subpoena. Instead, these issues are left to the State Court judge presiding over their case to decide. I. BACKGROUND The procedural background surrounding the Razorback Creditor's motion is important to t