Epstein Secrets

to the media and other third parties that adopt false and defamatory allegations about Dershowitz without qualification, including a statement by Jack Scarola, the attorneys' counsel in this case, to the Palm Beach Daily News on behalf of himself and Edwards and Cassell that "[w]hetherIMI=Is statements ar

luding evidence possessed by the government) that will help Jane Doe #3 respond to these unfair attacks [by Dershowitz]." 73. On January 7, 2015, Scarola issued a statement on behalf of Edwards and Cassell via PR Newswire that states, in relevant part, as follows: Mr. Dershowitz harshly attacks Mr. E

Amended Counterclaim, which expands on the factual allegations of Edwards's and Cassell's tortious conduct in several ways: • First, the proposed Second Amended Complaint asserts an additional count for defamation based on the attorneys' actions in asserting the unsubstantiated and irresponsible allegation that Dersh

e and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 2nd day of March, 2018. /s/ David P. Vitale Tr. JACK SCAROLA Florida Bar No.: Minn DAVID P. VITALE JR. Florida Bar No.: 115179 Attorne E-Mails: and Primary E-Mail: Searcy Denney Scarola Barnhart & Shiple

ay of March, 2018. /s/ David P. Vitale Tr. JACK SCAROLA Florida Bar No.: Minn DAVID P. VITALE JR. Flor

e four abandoned counts in an inoperative pleading that was no longer part of the record was now a nullity. 6. On August 21, 2011, Epstein filed a Second Amended Complaint against Defendant Rothstein. In his Second Amended Complaint, which supersedes the Amended Complaint, Epstein abandoned his Abuse of Process claim

0808486 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Reply was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 C

correct copy of this Reply was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards

e like this one, "a case where the case had never been at issue." Serban, 148 So. 3d at 1291(quoting Labor Ready). Furthermore, Epstein's operative Second Amended Complaint, which had neither been answered nor defaulted, contained a "brand-new" count alleged in response to the trial court's order dismissing the prior a

Mail on this 12th day of December, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

ERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail on this 12th day of December, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Go

lving your misconduct with minor females. Answer: If there is a contract for legal services relating to the damages claimed by Mr. Epstein in his Second Amended Complaint, it will be produced. Plaintiff objects to producing any and all other contracts for legal services in the defense of criminal charges or other civi

ry, 2012. Jack Flori.: No.: 169440 Se• enney Scarola Barnhart & Shipley, P.A. 21.9 alm Beach Lakes Bo

and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular,