Epstein Secrets

06/06/2012 PtChle°S of 22 Tonja Haddad Coleman From: Tonja Haddad Coleman Sent: Tuesday. May 29, 2012 10:47 AM To: 'Mary E. Pirrotta' Cc: 'Jack Scarola' Subject: RE: Edwards adv. Epstein Jack: To avoid any further miscommunications, misunderstandings, attempts to circumvent or delay the legal proc

an From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein disco

ing but not limited to, Scott Rothstein, Russell Adler, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan, Gary Farmer and Bradley Edwards, on the one hand, and any of the following regarding Jeffrey Epstein: 2 EFT

ds, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 954-524-2820 954-524-2822 - fax Attorneys for Defendant, LM. Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 686-6300 383-9424 F Attorneys for D

24-2822 - fax Attorneys for Defendant, LM. Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

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,

tographs . ...? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. Id. at 199, lines 25, 1-12. Q. [regarding Patrick Roberts] Did he ever perform investigation work on any of the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and ins

ng was emailed and mailed this gay of February, 2011 to Marc S. Nurik, Esq., One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. seph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BU

, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O.

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

the rules of the Court. I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed, faxed and emailed on this day of May, 2011 to Jack Scarola, Searcy Denney Scarola Barnhart EFTA00583201 & Shipley, Attorneys for Bradley J. Edwards, 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33

ed and emailed on this day of May, 2011 to Jack Scarola, Searcy Denney Scarola Barnhart EFTA00583201 &

2008 to the present: a. Rothstein; b. Edwards; c. Russell Adler; d. William Berger; e. Mike Fisten; f. Ken Jenne; g. Wayne Black; h. Patrick Roberts; i. Patrick Diaz 2. All written communications between you and any of the following employees, independent contractors, attorneys, partners, sha

ents or other representatives and persons purporting to be affiliated with such law firm. 10. "Searcy Denny" means the law firm of Searcy, Denney, Scarola, Barnhart & Shipley, P.A. and any of its past or present employees, independent contractors, attorneys, partners, shareholders, investigators, agen

ents or other representatives of or persons purporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be