Epstein Secrets

01 By: JACK GOLDBERGER, ESQUIRE ON BEHALF OF THE DEFENDANT(S): nvNNEY, gCnvOLA, ot—aL 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 By: JACK SCAROLA, ESQUIRE PA I \1 BEACH RBI,OkTINo SERVICE, INC. 561-fil -2995- PIIRS@PalmBeackRep?rting.com EFTA00617908 3 PROCEEDINGS 2 3 4 5 6 7 8 9

MR. BREWER: Yes. They make reference to the Schwartzle case. 17 18 19 20 21 22 23 24 25 Interestingly enough, he was represented by Mr. Scarola. Also represented by me at one time or another. I know Kathy Schwartzle. In that case, they cite language that talks about, you don't know what th

forever. And there is no reference to what the remedies would be. So under the guidance of Schwartzle, the criteria that had been laid out by the Fourth DCA have clearly not been met. That's defect Number 1 in the confidentiality provision. Defect Number 2 is that obviously because this confidentialit

asked about whether there is any appellate authority that assists the Court in addressing this issue, and the answer to that question is there is Fourth DCA precedent that is in fact very directly on point. PALM BEACH REPORTING SERVICE, INC. 561-471-2995 PJW@PalTseacWPotftscp EFTA00617917 12 1 2

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:

esponse in Opposition to Epstein'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

0792813 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 MS. ROCKENBACH: Yes, Your Honor. THE COURT: Mr. Scarola? MR. SCAROLA: Yes, Your Honor. THE COURT: If I need them, I will ask for them. I have several bankers boxes' worth of materials here. I don't nee

ck is a DRAFT ONLY !!!! NOT PROOFREAD EFTA00792856 47 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 Fourth DCA decision called Frazier versus Security and Investments, 1993. What does Frazier tell us? Not only do we build off the US Supreme Court and say yo