Epstein Secrets

ives the privilege. United States v. Jones, 696 F.2d 1069, 1072 (4th Cir. 1982). The general rule applies here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied (incorrectly) that the e-mails were shared with Epstein's counsel by Mr. Scherer, counsel for Razorback. Thus, Edwards admits that he volu

es here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied (incorrectly) that the e-mails were sha

The key elements at issue in Edwards' claim are "the absence of probable cause for the prosecution, malice, and damages." See, e.g., Rivernider v. Meyer, 174 So. 3d 602 (Fla. 4th DCA 2015). Edwards' own statements in the e-mails are directly relevant to and go to the heart of Epstein's ability to dem

tein respectfully seeks reconsideration and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA00808220 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Gol

on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Esq. Searcy Denney Scarola et al. 16 EFTA0080

Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, P.A., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 604-05 (Fla. 4th DCA 2015) (trial court properly entered summary judgment against malicious prosecution claimant where underlying

By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Counter-Plaintiff: Procedure 1.440 first. SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0

SEARCY, DENNEY, SCAROLA, BARNHART C 8 SHIPLEY, P.A. e MR. SCAROLA: Good morning, Your Honor. With the Court's permission, believe it or 9 By JACK SCAROLA, ESQUIRE :0 not, there is ono agreed matter that we 10 By DAVID P. VITALE JR., ESQUIRE 11 would ask the Court to address first. By KAREN TERRY

this Court wore absolutely true when 25 Mr. Rothstein, and that ho was in federal 2$ she said them. They are absolutely true 14 16 1 prison. Meyer before did Mr. Edwards raise today. This la not us not being ready. 2 this issue that ho raised on Friday. 2 This a legal defect that cannot be

ruling on the issue of probable cause, and an opportunity for the parties to be heard at oral argument on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA00799363 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . • Atterbury,

on this motion. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 25 EFTA0079

. Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, M., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 604-05 (Fla. 4th DCA 2015) (trial court properly entered summary judgment against malicious prosecution claimant where underlying p

The Last Word with O'Donnell — MSNBC (Jan. 8, 2015). Following these statements, on January 6, 2015, attorneys Edwards and Cassell, represented by Jack Scarola, Esq., filed a defamation action in Broward County Circuit Court. See Exhibit 11 at 1117 (alleging Dershowitz has "initiated a massive public media

ged information you would seek from me, I would then be able to decide whether to cooperate." See Exhibit 12 (emphasis added). On August 23, 2011, Scarola sent a letter to Dershowitz, explaining that there was no intent to inquire about attorney-client information, but adding: "[wje do, however, have r

no legal detriment arising from a default judgment against Hubbard." Id. at 1093 (Coffin, J., concurring). See also Edmondson". State of Neb. a rel. Meyer, 383 F.2d 123, (8th Cir. 1967) ("The mere fact that Edmondson's reputation is thereby injured is not enough [to support intervention]. Edmondson's

nt. I HEREBY CERTIFY that a true copy of the foregoing was furnished to all counsel on the attached service list, by email, on September 25, 2017. Jack Scarola, Esq. SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 WM, BURLINGTON & ROCKENBACH, P.A. C

, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 20 561.686.6300 BY: JACK SCAROLA, ESQUIRE 21 JSX@searc

r the prosecution and bona fide termination in the plaintiff's favor are two of six elements of a claim for malicious prosecution. See Rivernider v. Meyer, 174 So.3d 602, 604 (Fla. 4th DCA 2015) (noting the six elements to a malicious prosecution claim: 1) the commencement of a judicial proceeding; 2)

The Last Word with O'Donnell — MSNBC (Jan. 8, 2015). Following these statements, on January 6, 2015, attorneys Edwards and Cassell. represented by Jack Scarola, Esq.. filed a defamation action in Broward County Circuit Court. See Exhibit II at ¶ 17 (alleging Dershowitz has "initiated a massive public media

ged information you would seek from me, I would then be able to decide whether to cooperate." See Exhibit 12 (emphasis added). On August 23, 2011, Scarola sent a letter to Dershowitz, explaining that there was no intent to inquire about attorney-client information, but adding: "[w]e do. however, have r

o legal detriment arising from a default judgment against Hubbard." Id. at 1093 (Coffin. J.. concurring). See also Edmondson. Stale of Neb. ex. rel. Meyer. 383 F.2d 123, (8th Cir. 1967) ("The mere fact that Edmondson's reputation is thereby injured is not enough [to support intervention]. Edmondson's

to be heard at oral argument regarding any assertions by Edwards attempting to refute the existence of probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldber er, Es . Atterbury, Goldberger, & Weiss, P

probable cause. TONJA ET AL. SERVICE LIST Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

Wicker, Smith, Blomqvist, Tutan, O'Hara, McCoy, Graham & Lane, P.A., 613 So. 2d 1336 (Fla. 3d DCA 1993) (emphasis supplied); see also Rivernider v. Meyer, 174 So. 3d 602, 604-05 (Fla. 4th DCA 2015) (trial court properly entered summary judgment against malicious prosecution claimant where underlying p

February , 2015: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes

402 So. 2d 425 (Fla. 4th DCA 1981) 21 R.H. Ciccone Properties, Inc. v. JP Morgan Chase Bank, 141 So. 3d 590 (Fla. 4th DCA 2014) 15 Rivernider v. Meyer, Case Number 4D14-819 10 SCI Funeral Services of Florida, Inc. v. Henry, 839 So. 2d 702 (Fla. 3d DCA 2002) 22 Steinberg v. Steinberg, 152 So.

ris SERVICE LIST: William B. King Searcy Denny Scarola Barnhart & Shipley, P.A. Philip M. Burlington

69 So. 3d at 1206 (quoting Alamo Rent—A—Car, Inc. v. Mancusi, 632 So.2d 1352, 1355 (Fla.1994)). The holding in Fischer was restated in Rivernider v. Meyer, No. 4D14-819, 2015 WL 5244635 (Fla. 4th DCA Sept. 9, 2015) as follows: -10- EFTA00612492 Recently, in Fischer v. Debrincat, 40 Fla. Weekly D163