Epstein Secrets

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,

of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the pe

w.palmbeachdailvnews.com on October 15, 2010, entitled "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr.

CASE NO. 50 2009 CA 040800 XXXXMB AG Involved in a Civil Suit with a Lawyer." (Exhibit 4). The source for much of that article's information is Mr. Scarola, who is quoted to have said the following (Id.): a. "We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epste

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

w.palmbeachdailvnews.com on October 15, 2010, entitled "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr.

a New Criminal Investigation and is Involved in a Civil Suit with a Lawyer." (Exhibit 4). The source for much of that article's information is Mr. Scarola, who is quoted to have said the following (Id.): a. "We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epste

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra