Epstein Secrets

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00799400 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

ions on page 228 lines 1 though 13, Edwards admits that he received written and oral reports from investigators — before he answers though, he asks Scarola if he should answer and Scarola says "yeah." Id. at 229. The discussion turns to the manner in which the cases were handled while Edwards was a pa

Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799426 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

ims that I've settled cases for $200-million, which is totally not true. She has made claims of serious sum of money, which is outrageous. BY MR. SCAROLA: Q. How much have you settled claims for? MR. PIKE: going to instruct you not to answer that question. MR. SCAROLA: And the basis of that instruc

treet Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 facsimile EFTA00582842 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . • Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & We

king of Epstein's affidavit is warranted. Edwards does not contend that Epstein failed to comply with a court order as contemplated by Rule 1.380 of the Florida Rules of Civil Procedure; nor does Edwards assert that Epstein's affidavit contains material that should be stricken from a pleading as delineated in Rule 1.140 o

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585371 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

ions on page 228 lines 1 though 13, Edwards admits that he received written and oral reports from investigators — before he answers though, he asks Scarola if he should answer and Scarola says "yeah." Id. at 229. The discussion turns to the manner in which the cases were handled while Edwards was a pa

neys for Epstein 25 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585418 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585392 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

counsel before noticing hearing by review of J. Scarola's proposed Pre-Trial Stipulation and last version

mended Exhibit and Witness Lists AMM Analyze case law in support of our Supplemental Motion for 1.10 434.50 Continuance pursuant to Rule 1.460 of the Florida Rules of Civil 395.00/hr Procedure AMM Conduct research re how do we authenticate website articles and 2.10 829.50 website postings 395.00/hr AMM Prepare me