Epstein Secrets

ue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] 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

ted Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

; Lake Shore Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf

ives the privilege. United States v. Jones, 696 F.2d 1069, 1072 (4th Cir. 1982). The general rule applies here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied (incorrectly) that the e-mails were shared with Epstein's counsel by Mr. Scherer, counsel for Razorback. Thus, Edwards admits that he volu

es here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied (incorrectly) that the e-mails were sha

stence is necessary before a judicial determination can be made as to whether the contents are privileged." Id. The exception initially outlined in Hickman developed over time and is now memorialized in Florida Rule of Civil Procedure 1.280(b)(4): Under Florida law, party may obtain an opponent's alleg

, P.A. 2290 10a Avenue North Suite 404 Lake Worth, FL 33461 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 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

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

; Lake Shore Radiator. Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v, Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf

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

f litigation.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawye