Epstein Secrets

EREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 11th day of February , 2009: Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Bamhart & Jack Alan Goldberger Phone Phone Fax Fax Co-Counsel for Defendant Jeffrey Epstein

s on this 11th day of February , 2009: Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola

hich might possibly lead to evidence supporting some subsequent cause of action is quashed. COBB and PETERSON, IL, concur. Fla.App. 5 Dist.,2001. State Farm Mut. Auto. Ins. Co. v. Parrish O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. Page 2 http://web2.westlaw.corn/print/printstream.aspx?sv

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,

r procedure is for the trial court to examine the disputed documents in-camera and remove those documents which fall into the privileged category." State Farm Mut. Auto. Ins. Co. v. Kendrick, 780 So. 2d 231, 233 (Ha. 3d DCA 2001) (error for trial court to order production of documents allegedly protected by a

EREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 11th day of February , 2009: Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. Bamhart & Counsel for Plaintiff Co-C

s on this 11th day of February , 2009: Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarol

hich might possibly lead to evidence supporting some subsequent cause of action is quashed. COBB and PETERSON, IL, concur. Fla.App. 5 Dist.,2001. State Farm Mut. Auto. Ins. Co. v. Parrish O 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works. http://web2.westlaw.corn/print/printstream.aspx?sv=Split&p

e 26, 2014. William B. King, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes

decision to accept or reject. See Nationwide Mut. Fire Ins. Co. v. Pollinger 42 So.3d 890, 891 (Fla. 4th DCA 2010). As the Supreme Court has noted State Farm Mut. Auto Ins. Co. v. Nichols, 932 So.2d 1067, 1079 (Fla. 2006): The rule intends for a proposal for judgment to be as specific as possible, leaving n