Epstein Secrets

OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury,

Mail on this 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

A040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ revealing relevant information in pretrial discovery." (emphasis added). The Fourth District explained in Brancaccio that the "Supreme Court has disapproved of procedures which require a party to surrender one constitutional right in order

other than Mr. Epstein and his co-counsel, that there have been no eyes laid upon these documents. Hence accepting that representation, as Mr. Scarola has accepted those representations during the hearing as well. (3/8/18 Aft. Tr. 78:9-25) (emphasis added). Paul Cassell, the Intervenors' couns

J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: FBN Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 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-

dwards, 4'h DCA Case No. 4D18-0787. (Composite Exhibit C.) CONCLUSION Epstein's general references in pre-trial filings with this Court and in the Fourth District Court of Appeal to the 47 exhibits in question are fully compliant with the Court's rulings at the March 8, 2018 hearing. Epstein has not dissemina

, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 JSX@searc

dwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 [email protected] BY: WILLIAM B. KING, ESQUIRE 22 [email protected] 23 24 25 www.phippsreporting.com 888 811-3408 EFTA00606511

efore them 3 because it had already been determined that the 4 litigation privilege applied to the abuse of 5 process in both the Third and the Fourth District 6 Courts of Appeal. That's admitted by 7 the counterclaim in their motion in opposition. g I wanted to speak about this idea that the 9 worst

By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0

SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0 not, there is ono agreed matter that we 10 By DAVID P. VITALE JR., ESQUIRE 11 would ask the Court to address first. By KAREN TERRY

t for record, the case I keep on my bunch is Palm Beach Polo holdings, Inc., et. al versus Broward Marino, Inc. I have the original email from the Fourth District Court of Appeal copy. So I don't have a cite for you, but it's from 2015. That's easily accessible if you'd like to road it. MR. LINK: Thank you.

4 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611634 SERVICE LIST - CASE NO. 502009CA040800XXXXlVIBAO Jack Scarola, Esq. [email protected]; [email protected] Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, E

CE LIST - CASE NO. 502009CA040800XXXXlVIBAO Jack Scarola, Esq. [email protected]; [email protected] Sear

re, hereby requests that this Court stay these proceedings until the Florida Supreme Court renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla.

follows: And I 7 8 am going to touch first a little bit on the 8 On behalf of the Defendants: 9 response because they claim that there is 9 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 10 additional discovery to be done, but they don't 10 BARNHART & SHIPLEY, P.A. 11 identify any discovery tha

h first a little bit on the 8 On behalf of the Defendants: 9 response because they claim that there is 9 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 10 additional discovery to be done, but they don't 10 BARNHART & SHIPLEY, P.A. 11 identify any discovery that they wish to do. 2139 Palm Beac

equires more; namely, an act which constituted 18 claims for malicious prosecution. And it's a 18 misuse of the process after it was issued. 19 Fourth District, so I am going to go to that 19 There is no such allegation of a post-issuance 20 case first. 20 act other than service of what was issued unde

01 By: JACK GOLDBERGER, ESQUIRE ON BEHALF OF THE DEFENDANT(S): nvNNEY, gCnvOLA, ot—aL 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 By: JACK SCAROLA, ESQUIRE PA I \1 BEACH RBI,OkTINo SERVICE, INC. 561-fil -2995- PIIRS@PalmBeackRep?rting.com EFTA00617908 3 PROCEEDINGS 2 3 4 5 6 7 8 9

MR. BREWER: Yes. They make reference to the Schwartzle case. 17 18 19 20 21 22 23 24 25 Interestingly enough, he was represented by Mr. Scarola. Also represented by me at one time or another. I know Kathy Schwartzle. In that case, they cite language that talks about, you don't know what th

R. SCAROLA: Yes, your Honor. THE COURT: Okay. So the language was utilized from Levin and Etchaverria in order to support the oral decision in the Fourth District Court of Appeal. But again, the fact that the argument in good faith may erode the ethics argument doesn't dispel the concern that the Court has,

cuments re same; multiple communications with J. Scarola re production issues; follow up with client re s

. Rockenbach to have in the pipeline, pending outcome of 3/8/18 hearing; review appellate rules of procedure on certiorari and mandamus relief and Fourth District Court of Appeal's Administrative Order re requests for emergency relief 03/04/18 SJL Work on strategies re case not at issues, Petition for Cert

B [t S 03/22/18 RJG R D fc • 03/22/18 RJG C c; 03/22/18 RJG C h. Inspection; work on it of Certiorari; work on Ause in Bankruptcy . Scarola and D. Vitale .c -Ind changes to •?ction to Unilaterally as with J. lanno re hearing attendance; yke Ile and J. Scarola re ;19 style of case;

e all r. 90.702, work-product pr inethical behavior, is; onse in Opposition to Pr eider from the Fourth Di P. Cassell's Pro Hac Vi. ) the Fourth District Cc Ida+ for panel purposes 03/17/18 TLC Cr c, ionology of Ix i, .; review court filings, tr; r re same 03/17/18 SJL C( ) I Edwards' Resp

- CASE NO. 502009CA0408003000CMBAG Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Be

re, hereby requests that this Court stay these proceedings until the Florida Supreme Court renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla.