Epstein Secrets

E OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger

. Mail on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm B

very issues. EFTA00613622 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 3. At the hearing on September 28, 2011 on Edwards' Motion to Dismiss the Second Amended Complaint, this Court reiterated that it wanted to get the issues in the pleadings resolved before addressing discove

er than Mr. Epstein and his co-counsel, that there have been no eyes laid upon these documents. Hence, I'm 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

N Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST 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

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

hearing indicated that Edwards' burden was proving no probable cause at the time Epstein filed the original civil proceeding and Edwards' counsel, Jack Scarola, corrected him and stated: We contend there was no probable cause to continue the proceeding. The initiation and continuation of the proceeding cau

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

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

clients (MI., M. and Jane Doe) of claims they brought against Epstein: 3 EFTA00808635 24 THE COURT: The only thing I would say 25 to that, Mr. Scarola, is I don't want to mix 1 apples and oranges. And that is, I don't 2 want to place the Court's incriminator [sic] on 3 getting too far afield and

y: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Reach. FL 33409 Co-Counsel for Defendant/Counter-Plainti

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

y: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel Jro DeJendan&Counter-Plaintif

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

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

ary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST 5 EFTA00808730 Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, •. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plainti

Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST 5 EFTA00808730 Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, •. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter

rder. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Bu

FY that a true and correct copy of this Petition was furnished via email this 12th day of March, 2018: Jack Scarola Karen E. Terry Searcy, Denny, Scarola, Barnhart & Shipley, P.A. o- ounse en yard an counter- PlainOT Bradley J. Edwards Nichole J. Segal Burlin ton & Rockenbach P.A. 350 Co-Coun

nday, March 5, 2018, Epstein filed his to motion to remove the case from trial docket in order to comply with the mandate of Rule 1.440 and opposed Edwards' Motion for Pursuant to the clear language of the rule, if the action involves a main claim or counterclaim which has neither been answered nor defaulted,

G Order Specially Setting Hearing COUNSEL LIST Jack Scarola Es . Searcy Denney Scarola Barnhart & Shipley PA

der Specially Setting Hearing COUNSEL LIST Jack Scarola Es . Searcy Denney Scarola Barnhart & Shipley PA

V. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' Motion in Limine to Strike the June 30, 2017 Affidavit of Jeffrey Epstein and to Exclude Evidence as to which Discovery was withheld under Claims of Privil