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tein respectfully seeks reconsideration and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA00808220 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Gol
on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA0080
t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution ac
COUNTY, FLORIDA 2 Videotaped Depoeitien ofWILLIAMBERGER Page lb. Case No. 502009CA040800XXXXMB 4 JEFFREY EPSTEIN, 5 Direct Examination by Hr. Scarola 5 Plaintiff/Counter-Defendant, 4 Cross-Lamination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individuall
16 MR. LINK: Sure. Scott Link on behalf 26 2139 Palm Beach Lakes Boulevard 17 of plaintiff, Jeffrey Epstein. West Palm Beach, FL 33409 27 By JACK SCAROLA, ESQUIRE 19 MR. INDYKE: Darren Indyke on behalf of la 19 plaintiff, Jeffrey Epstein. 19 ALSO PRESENT 20 MR. SCAROLA: My name is Jack Scarola
So I served on the 12 Fourth District and served with a panel of judges 13 and heard quite a number of cafes and wrote several 14 decisions for the Fourth District. Q The jury may not be familiar with the 14 procedure, but when the appellate court reviews 17 decision➢ that are rendered and jury trial re➢ul
ruling on the issue of probable cause, and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury,
on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA0079
t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution act
2 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: For Bradley Edwards: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE, JR. For Bradle
PPEARANCES: For Bradley Edwards: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE, JR. For Bradley Edwards: BURLINGTON & ROCKENBACH PA 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 By
cted the summary judgment on probable cause and bona fide termination. We filed an appeal. That case was briefed. And prior to the oral argument, the Fourth District rejected the Wolfe case. Now, what happened in the briefing in our case is our initial brief addressed solely litigation privilege, because that
e 26, 2014. William B. King, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes
y to make an informed decision of acceptance or rejection. One aspect of Swartsel was disagreed with by the Supreme Court in Nichols. In Swartsel, the Fourth District held parties were required to specify all terms of a settlement (882 So.2d at 453). Then in Nichols, the Supreme Court held parties could summarize
Entities connected to both Jack Scarola and the Fourth District

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJane Doe
PERSONMaria Farmer
PERSON
George W. Bush
PERSONPalm Beach Lakes Boulevard
LOCATION
Alan Dershowitz
PERSONSpencer Kuvin
PERSONBruce E. Reinhart
PERSONRobert C. Josefsberg
PERSON
Kenneth Marra
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Donald Trump
PERSONTonja Haddad Coleman
PERSONGoldberger & Weiss
ORGANIZATIONMichael J. Pike
PERSONAtterbury
ORGANIZATIONSearcy Denney Scarola
PERSON