Epstein Secrets

trike Edwards' expert. Epstein disclosed his expert a mere two months after Edwards' expert's report was disclosed. 4 EFTA00808424 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co

ths after Edwards' expert's report was disclosed. 4 EFTA00808424 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards

expert which is otherwise qualified to testify to what he's going to testify. (3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which should pertain in only the most compelling

his deposition you said, look, here's public records that you probably are not totally aware of, you may be, you may not be, but here they are. Mr. Scarola may have objected, may have requested the termination of the deposition to seek a protective order so that he, Mr. Edwards, would have the opportun

ra Berard Rockenbach (FBN Primary: Primary: Secondary: Secondary: Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00808712 SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-

l by way of memorandum, and that will be done under seal and will continue to be under seal, and will be filed under seal in case of Ringer v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2 EFTA00808705 a need for appellate review. So that is going to be the direction of the Court, that the motion be

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

annot have his cake and eat it too. Simply put, actions speak louder than words. 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

Link & Rockenbach, PA discovered documents that were voluntarily produced years ago by Edwards to his potential adversaries at the 6Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 3 EFTA00794279 time — the Razorback plaintiffs. These e-mails directly contradict Edwards' sworn testimony and pos

his deposition you said, look, here's public records that you probably are not totally aware of, you may be, you may not be, but here they are. Mr. Scarola may have objected, may have requested the termination of the deposition to seek a protective order so that he, Mr. Edwards, would have the opportun

M By: Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903 Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00794306 SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 m

that any substantive discussion of those emails will be done under seal by way of memorandum, and that will be done under seal and 'Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2Excerpts of the November 2, 2018, Hearing Transcript are attached as Exhibit A. 2 EFTA00794299 will continue to b