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

6 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mai Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, Jones, Esq., Assistant

y written or oral statements made to the Federal Bureau of Investigation ("FBI"), including but not limited to the statement cited by your counsel, Jack Scarola, in the October 15, 2015 deposition of Dershowitz in the following line of questioning: Mr. Scarola: Do you have a copy of the statement that mad

d to the statement cited by your counsel, Jack Scarola, in the October 15, 2015 deposition of Dershowitz in the following line of questioning: Mr. Scarola: Do you have a copy of the statement that made to the FBI? Mr. Dershowitz: I don't have it here, no. Mr. Scarola: Have you seen it? Mr. Dersho

3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

ed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409, as well a

ectronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley,

2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

y written or oral statements made to the Federal Bureau of Investigation ("FBI"), including but not limited to the statement cited by your counsel, Jack Scarola, in the October 15, 2015 deposition of Dershowitz in the following line of questioning: Mr. Scarola: Do you have a copy of the statement that mad

d to the statement cited by your counsel, Jack Scarola, in the October 15, 2015 deposition of Dershowitz in the following line of questioning: Mr. Scarola: Do you have a copy of the statement that made to the FBI? Mr. Dershowitz: I don't have it here, no. Mr. Scarola: Have you seen it? Mr. Dersho

7 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

ed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409, as well a

ectronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley,

1 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Pl

s been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409; to: Joni

al and thus served by electronic mail: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley,

8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been electronically filed through the Clerk of Broward County by using the Florida Courts eFiling Portal and thus served by electronic mail: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach

bstance of her communications with Plaintiffs, including through her disclosure of and reliance on a 2011 interview with Edwards and John Scarola ("Scarola"), Plaintiffs' counsel in this action, that was labeled "Privileged .. . and/or Work Product." • Plaintiffs have waived their right to rely on the

2843 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been furnished by electronic mail (email) at email address: to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409, as well a

laintiff Cassell, 160 East 300 South, Salt Lake City, Utah 84114, and I electronically filed the foregoing with the Clerk of Broward County by using the Florida Courts eFiling Portal this 24th day of November, 2015. By: s/Thomas E. Scott THOMAS E. SCOTT FBN: 149100 10 EFTA00622844