Epstein Secrets

afele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack Scarola, Esq. Karen Terry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL

GENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes

ATE OF SERVICE 29 ii EFTA00808516 TABLE OF AUTHORITIES CASES PAGE Abrams v. Paul, 453 So.2d 826 (Fla. 1st DCA 1984) 17 Alamo Rent-A-Car v. Mancusi, 24 632 So.2d 1352 (Fla. 1994) Bennett v. Continental Chemicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A.

likely default by Rothstein, the identical allegations will be terminated in Epstein's favor, a directly opposite result). See Alamo Rent-A-Car v. Mancusi, 632 So.2d 1352 (Fla. 1994). Thus, Edwards's malicious prosecution claim was not a compulsory counter-claim and would at best be considered a permi

k, will you please introduce who is sitting at the table with you? DefendantICounter-Plaintfrs Counsel: The attorney on this side of the courtroom, Jack Scarola, represents Bradley Edwards, one of the defendants who has been sued and who brought a counterclaim against Mr. Epstein. His job is to present his c

dary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff1Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards

in's position this will allow the jury to better understand why they are being instructed on probable cause, malice, etc.; Alamo Rent-A-Car Inc. v. Mancusi, 632 So. 2d 1352 (Fla. 1994); Rivernider v. Meyer, 174 So. 3d 602 (Fla. 46 DCA 2015); Hickman v. Barclay's Intl Realty, Inc., 16 So. 3d 154, 155 (Fl

afele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack Scarola, Esq. Karen Terry, Esq. David J. Vitale, Jr. Esq. SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL

ott J. Link FBN 602991 Primary: Secondary: Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach FL 33409 ter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington

, the facts this Court will consider when it determines whether Defendant has proved Plaintiff lacked probable cause. See Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352, 1357 (Fla. 1994) (jury decides disputed issues of fact, but court determines whether those facts establish probable cause) (citati

tled to compensation for his time participating in litigation when he engaged counsel to represent him in the matter). Since Edwards has engaged Mr. Scarola from the outset of this case to represent him, Edwards cannot claim as damages his time assisting counsel or involvement in the subject litigation

py of the foregoing has been duly furnished via G Email, G Facsimile, G U.S. Mail, G Hand Delivery, G Federal Express this day of April, 2012 to: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. P.O. Drawer 3626 West Palm Beach, FL 33409 Jack Alan Goldberger,

ion are recoverable by Edwards because there was no prior lawsuit that ended with a "bona fide termination" in his favor. Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352 (Fla. 1994). In order to comply with the Court's order to address damages, Epstein needs to incorporate certain arguments previousl

ris SERVICE LIST: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. Philip M. Burlington

dant, and (6) the plaintiff suffered damage as a result of the original proceeding." Fischer, 169 So. 3d at 1206 (quoting Alamo Rent—A—Car, Inc. v. Mancusi, 632 So.2d 1352, 1355 (Fla.1994)). The holding in Fischer was restated in Rivernider v. Meyer, No. 4D14-819, 2015 WL 5244635 (Fla. 4th DCA Sept. 9,