Epstein Secrets

nkrocklaw.com Secondary: [email protected] Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 12 EFTA00805169 SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] Nichole J. Segal B

[email protected] Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 12 EFTA00805169 SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] Nichole J. Segal Burlington & Rockenbach,

Tort Claimants and possibly others. Epstein denies this motivation EFTA00805158 and maintains his probable cause was grounded in media reports of the Rothstein Ponzi scheme and the realization of the possible connection for Edwards' litigation behavior unrelated to the claims of his three clients. Court's Rulin

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 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury,

Mail on this 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

btain summary judgment. Third, Edwards has not demonstrated the absence of material issues of fact. His alleged participation in and/or knowledge of the Rothstein Ponzi scheme and the validity of, and motivation in conducting, the discovery at issue in the underlying Epstein actions are matters of considerable deba

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

correct copy of this Petition was furnished via email this day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. 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

aim against both Rothstein and Edwards) in connection with the use of Epstein case materials, which were improperly utilized to lure investors into the Rothstein Ponzi scheme is clearly and irrefutably related to Edwards' counterclaim against Epstein for filing that original claim. Yet, to mislead this Court into

March 23, 2010, counsel to Epstein deposed Edwards. During that examination, Edwards refused to answer numerous questions to which he or his counsel Jack Scarola objected. For example, he was asked generically about RRA's document storage system: Q. And what type of information did you put into Q-task regard

gh Edwards could have answered the question without disclosing information intended to be kept confidential by his client L.M3 Id. at 99. 10. Mr. Scarola also erroneously counseled Edwards not to answer a series of question about his communications with federal prosecutors: ". . .do you know whether,

in a case like this where incentives offered to Edwards and accepted by Edwards are plainly relevant to a determination of whether he was privy to the Rothstein Ponzi scheme and why he decided even to join RRA. It is significantly relevant to his counterclaim since he is claiming loss of profits and injury to his