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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,
did not have to respond to questioning regarding the initial conversation that took place between Diaz and him. On petition for writ of certiorari, the Third District concluded that the trial court had departed from the essential requirements of the law by directing that Rabin need not respond to questions about w
z 22 EFTA00582670 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- mail on May 9, 201 to: Jack Scarola, Esquire, Searcy Denny et al and counsel for Plaintiffs, and to Sigrid McCawley, Esquire, Boies Schiller & Flexner, counsel for Jane Doe No. 3, a
ing was sent via E- mail on May 9, 201 to: Jack Scarola, Esquire, Searcy Denny et al and counsel for P
tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed
ail on May 6, 2015,46,; S-204544ar554046 to: Jack Scarola, Esquire, Searcy Denny et al and counsel for Pl
CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E- mail on May 6, 2015,46,; S-204544ar554046 to: Jack Scarola, Esquire, Searcy Denny et al and counsel for Plaintiffs, and to Sigrid McCawley, Esquire, Boies Schiller & Flexner, counsel for Jane Doe No. 3, at
tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed
e 26, 2014. William B. King, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes
e, even though Epstein is a non-lawyer. This Court dismissed Edwards' lawsuit, concluding it was bound under case precedent from a single case from the Third District to apply the litigation privilege. Epstein seeks attorneys' fees pursuant to his Proposal for Settlement served in 2011. Over Edwards objection, I
Entities connected to both Jack Scarola and the Third District

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONTonja Haddad Coleman
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONPalm Beach Lakes Blvd
LOCATION
Bill Clinton
PERSON
Virginia Giuffre
PERSON
United States
LOCATIONthe Southern District
LOCATION
U.S. Virgin Islands
LOCATION
David Boies
PERSON