Epstein Secrets

aw.com 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale, Jr., Esq. Florida Bar No.: 115179 Attorney E-Mails: [email protected]; and [email protected]

561-727-3601 Attorneys for Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale,

ned in violation of an order from U.S. I EFTA00808132 Case 09-34791-RBR Doc 6384 Filed 05/14/18 Page 2 of 6 Bankruptcy Judge Raymond B. Ray of the Bankruptcy Court for the Southern District of Florida. See DE 1194, In Re: Rothstein Rosenfeld: Adler, P.A., No. 09-34791-RBR. If you are in possession of any of t

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-

ng, Edwards, himself, would be in violation of the Court's ruling by his reference to the e-mails in filings in this Court, the Appellate Court and the Bankruptcy Court. In fact, Epstein has taken numerous affirmative steps to ensure compliance with the Court's directives at the March 8, 2018 hearing. The disc is se

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-

any argument for an in camera review or other relief with respect to the e-mails in this Court or the appellate court or from defending himself in the Bankruptcy Court." 13 EFTA00808716 B. Fourth DCA D.E. Date Document 03/14/18 Epstein's Response in Opposition to Edwards' Motion for Partial Relief from St

e and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 16ih day of April, 2017. /s/ David P. Vita& Jr. JACK SCAROLA Florida Bar No.: 169440 KAREN E. TERRY Florida Bar No.: 45780 DAVID P. VITALE JR. Florida Bar No.: 115179 Attorne E-Mail s : and Primary E-Ma

day of April, 2017. /s/ David P. Vita& Jr. JACK SCAROLA Florida Bar No.: 169440 KAREN E. TERRY Florida

f Epstein's deposition. I The Court recognized that the privileged materials at issue were likely subject to an order from Judge Raymound B. Ray of the Bankruptcy Court for the Southern District of Florida. 3/8/18 Afternoon Session Tr. at 52:6-19; 54:9-20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is

da Bar No.: 132896 FARMER, JAFFE, WEISSING, EDWARD FIT LEHRMAN P.L. 16 EFTA00708308 Case 09-34791-RBR Doc 1603 Filed 0410811 Page 17 of 23 Jack Scarola Florida Bar No.: 169440 Searcy, Denney, Scarola, Barnhart & Shipley Attorney for Bradley J. Edwards in the matter of Epstein v. Edwards, et at Ca

T LEHRMAN P.L. 16 EFTA00708308 Case 09-34791-RBR Doc 1603 Filed 0410811 Page 17 of 23 Jack Scarola Florida Bar No.: 169440 Searcy, Denney, Scarola, Barnhart & Shipley Attorney for Bradley J. Edwards in the matter of Epstein v. Edwards, et at Case No.: 502009C40408000CCaMBAG 17 EFTA00708309

the obligation to file a privilege log does not arise."). B. Discovery Issues Related to the State Court Issued Subpoenas Are Not Properly Before the Bankruptcy Court The Razorback Creditors are also attempting to litigate issues relating to discovery in state court cases before this bankruptcy court. But neither

S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

VICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail and U.S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbur

f would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Edwards, in response to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA04

February , 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

ized that it has been "expansively interpreted" by Florida courts. In Microbilt Corporation v. Cher Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013), the Bankruptcy Court, applying Florida law, avowed: The rule of absolute immunity extends to the parties, judges, witnesses, and counsel involved and related to the jud

Attorney E-Mails: Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulev

er White's possession and retention of the CD at issue is currently the subject of a Motion for Issuance of an Order to Show Cause that was filed in the Bankruptcy Court on March 19, 2018. The Bankruptcy Court has scheduled a hearing on that motion for April 13, 2018. 4 EFTA00811314 Edwards adv. Epstein Case No.

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

Writ of Certiorari; work on Response to B. Edwards' Motion to Permit to Take the Limited Deposition of J. Epstein; review Farmer Jaffe's Motion in the Bankruptcy Court and the Bankruptcy Court hearing transcript for cites to reference in same Hours May 7, 2018 Page 10 Amount 6.20 4,650.00 0.10 0.00 3.90

February 25, 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

en "expansively interpreted" by Florida courts. In 13 EFTA00613602 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013), the Bankruptcy Court, applying Florida law, avowed: The rule of absolute immunity extends to the parties, judges, witnesses, and counsel involved and related to the jud