Epstein Secrets

4:13-14. However, when given the option to waive any technical argument under Rule 1.440, they declined to do so: MR. LINK: Thank you. I know Mr. Scarola said they're excited to try the case, believe me, Judge, we are really excited to try the case. The evidence that we recently discovered — THE C

CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all all Counsel on the attached list, this an day of July, 2018. c JACK SCAROLA Florida Bar No.: 169440 KAREN E. TERRY Florida Bar No.: DAVID P. VITALE JR. Florida Bar No.: Attome E-Mails: •••••••• ;and Primary E-Mail:

tein's Motion to Amend Exhibit List. McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) (citing Binger). As the Fourth DCA aptly stated in Tomlinson-McKenzie: The objecting party is prejudiced by the admission of such evidence if the party might have taken some action to protect itself had it had timely

Y CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 9 0-11--d:y of July, 2018. JACK SCAROLA Florida Bar No.: 169 DAVID P. VITALE JR. Florida Bar No.: Attorne E-Mail s : and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 21

hed list, this 9 0-11--d:y of July, 2018. JACK SCAROLA Florida Bar No.: 169 DAVID P. VITALE JR. Flori

n Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Renewed Motion for Leave to Disclose Expert Witness "expert" testimony. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) ("There was no finding that appellants failed to comply with the pretrial order in bad faith. Th

ims that I've settled cases for $200-million, which is totally not true. She has made claims of serious sum of money, which is outrageous. BY MR. SCAROLA: Q. How much have you settled claims for? MR. PIKE: going to instruct you not to answer that question. MR. SCAROLA: And the basis of that instruc

treet Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 facsimile EFTA00582842 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . • Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury, Goldberger, & We

her through a proper motion or at trial, so that this Court can properly examine the issue and rule on Edwards's request that it be precluded. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998); Aguila-Rojas v. City Management Group Corp., 606 So.2d 765, 766 (Fla. 3d DCA 1992). In the case