Epstein Secrets

NO. 50 2009 CA 040800 XXXXMB AG I HEREBY CERTIFY that a true and correct copy of the foregoing was faxed and mailed this Ze iday of August, 2011 to Jack Scarola, Esq., Searcy, Denney, Scarola, Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409. .).2a 01-0 Joseph L. Ackerman,

EREBY CERTIFY that a true and correct copy of the foregoing was faxed and mailed this Ze iday of August, 2011 to Jack Scarola, Esq., Searcy, Denney, Scarola, Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409. .).2a 01-0 Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLE

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

was served by e-mail on October 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 P

3 EFTA00807739 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by e-mail on October 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $20,000 for Edwards' claim for punitive damages. The total amo

is April 28, 2013. Electronic Service List Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Be

e and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this April 28, 2013. Electronic Service List Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, P

d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm

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

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

imary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, . Burlington & Rockenbach, 2139 Palm Beach Lakes Boulevard Courthouse Commons, Suit

ry: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, . Burlington & Rockenbach, 2139 Palm Beach Lakes Boulevard Courthouse Commons, Suite 350 West Palm Beach. FL 33409 444 West

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo

In West Palm Beach, P ch County. Florida this 3 day of 2015. Copies flints:led to: 4 O. a RAFELE CIRC. is JUDGE nit tit.. EFTA00617982 Jack Scarola, Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. 250 Australian Ave. South, Ste. 1400 West Palm Beach, FL 33401

EREBY CERTIFY that a true and correct copy of the foregoing was faxed and mailed this ac day of August, 2011 to Jack Scarola, Esq., Searcy, Denney, Scarola, Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409. 2.-O Joseph L. Ackerman, Jr. Fla. Bar No. 235954 WASOPOWROSFIli

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

109 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

rocess claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operative portion of the Fourth Amended Counterclaim is count two, malicious prosecution. In that complaint, Judge, against Mr. Epstein, Mr. Edwards asserts in paragraph 24, "While pro

3 EFTA00583921 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by e-mail on October 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley

was served by e-mail on October 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 P

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $100,000 for Edwards' claim for punitive damages . The total a

to be heard at oral argument regarding any assertions by Edwards attempting to refute the existence of probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, P

probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

EFTA00584565 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served by e-mail on October 20, 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley

served by e-mail on October 20, 2017, on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 P

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo