Epstein Secrets

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,

adverse party to show that the communication was not privileged. Leithauser v. Harrison, 168 So. 2d 95 (Fla. 2d DCA 1964); see also Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, 192-93 (Fla. 4th DCA 1991) ("[N]othing in the record indicates that any documents are protected by the attorney/client p

S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley,

VICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic mail and U.S. Mail on this IM day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbur

work-product privilege extends only to "materials in question [which]were prepared in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (F

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

ls to satisfy the particularity requirement if an ambiguity could reasonably affect the offeree's 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