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

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677,682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at depo

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

in the substantial equivalent of the materials by other means. A showing of need encompasses a showing of diligence by the party seeking discovery. Proctor & Gamble Co. v. Swilley, 462 So. 2d 1188, 1194 (Fla. 1st DCA 1985). And "No determine whether a moving party will experience undue hardship, courts must balance

, 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

under the Federal Rules is to obtain a full and accurate understanding of the true facts in order to obtain a fair and just result. United States v. Proctor & Gamble Co., 356 U.S. 677, 682, 78 S.Ct. 983 (1958). 16. Defendant should not have to rely on only those "handpicked" witnesses disclosed by Plaintiff at dep