Epstein Secrets

nference hearing 05/03/18 SJL Follow up with J. Scarola re trial setting; prepare for and attend status

whether a denial of writ petition without prejudice to appeal from final order Is a favorable disposition 05/09/18 KBR Conduct legal research re B. Edwards' citation to two cases as basis for conditional fee entitlement in certiorari proceeding; key cite cases and broaden search re 9.400 fee entitlemen

, 2018, dismissing mandamus petition as moot and denying both parties' fees); work on Response to B. Edwards' Motion for Hearing and Order denying B. Edwards' conditional entitlement to appellate fees; telephone conference with D. Indyke re Response, discussion re 9.400, discretion of appellate court, go

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail this day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury Gol

l and U.S. Mail this day of May, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley,

plaint. Until Epstein files a new complaint, there is simply no predicate for seeking punitive damages based upon Epstein's abuse of process claim. B. Edwards' Proffer Lacks the Requisite "Reasonable Basis" for Punitive Damages - 7 - EFTA00582886 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800

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

e page/line damage summary re B. Edwards deposition 1.10 434.50 testimony dated March 23, 2010 395.00/hr AMM Prepare page/line damage summary re B. Edwards' deposition 0.80 316.00 testimony dated May 15, 2013 395.00/hr 11/8/2017 TLC Continue working on preparations for B. Edwards' deposition; work

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;

th opposing counsel re hearing and production of audio; work on chronology; begin reviewing new public records 03/01/18 KBR Prepare objections to B. Edwards' deposition designations and consider counter-designations; attend trial team strategy meeting; prepare/revise motion to redact names and alter tri

Tecum in state court action; prepare email to J. Scarola's assistant re depositions of Fowler White and L

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li

2018 at 3:51 PM, Scott J. Link wrote: EFTA00799201 Judge Hateie denied Hotnstein motion to dismiss. Kara argued the motion. Nurick was there and Scarola. Nurick and Scarola were powwowing after the hearing. It's an important ruling for us to be able to tell the jury in Edwards that we still have a p

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li