Epstein Secrets

5467 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of this Response was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409

rect copy of this Response was furnished via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards

at Improperly and Without Foundation Claims Misconduct by Counsel The now sealed exhibits have never been deemed "apparently stolen" by my court. (Joinder, p. 1.) And neither Epstein nor his counsel has taken the "position that he need not immediately comply because of this Court's recent stay." (Joind

er than Mr. Epstein and his co-counsel, that there have been no eyes laid upon these documents. Hence, I'm accepting that representation, as Mr. Scarola has accepted those representations during the hearing as well. (3/8/18 Aft. Tr. 78:9-25) (emphasis added). Paul Cassell, the Intervenors' couns

N Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co

er- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION In order to justify his Motion for Sanctions, Edwards concocts a patently absurd construction of this Court's verbal ruli

other than Mr. Epstein and his co-counsel, that there have been no eyes laid upon these documents. Hence accepting that representation, as Mr. Scarola has accepted those representations during the hearing as well. (3/8/18 Aft. Tr. 78:9-25) (emphasis added). Paul Cassell, the Intervenors' couns

J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: FBN Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-

er- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION In order to justify his Motion for Sanctions, Edwards concocts a patently absurd construction of this Court's verbal ruli

B [t S 03/22/18 RJG R D fc • 03/22/18 RJG C c; 03/22/18 RJG C h. Inspection; work on it of Certiorari; work on Ause in Bankruptcy . Scarola and D. Vitale .c -Ind changes to •?ction to Unilaterally as with J. lanno re hearing attendance; yke Ile and J. Scarola re ;19 style of case;

re same 03/17/18 SJL C( ) I Edwards' Response to ,r1 mus and Motion to 03/18/18 TLC W )esponse to our Pe s, Request for Oral '. Cassell's Joinder; fo work on it ital Appendix; work or 03/18/18 RJG R ' second round of edits tc ng 03/18/18 SJL W -sell's Joinder; work or 'o 'se to o

P • • to Petitoner's Motion 0.30 0.00 fo ld Costs 03/19/18 TLC C. • Edwards' Response 9.80 2,205.00 to mus, Request for O. P. Cassell's Joinder at rk on Motion for tinue working on cl. .very . oduction issues; work on 03/19/18 SJL W Zesponse to our 8.20 6,150.00 Pr Request for O

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

witz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, P

cuments re same; multiple communications with J. Scarola re production issues; follow up with client re s

late to opposing counsel for review in advance of hearing; work on Response to Farmer Jaffe's Motion to Show Cause in bankruptcwork on Response to Joinder filed by Intervenors ., E.W. and Jane Doe 04/03/18 SJL Work on insurance demand to Fowler White; work on Motion for In Camera Review; review pro

e defense attorneys’. Moreover, because the first time Jane Doe #3 made these contemptible allegations against Prof. Dershowitz was in her Motion for Joinder in December 2014, those allegations are irrelevant as to the inquiry of whether Jane Doe #3’s rights under the CVRA were violated at the time the NPA

to Intervene at 13.) In support of this allegation, Jane Doe #3 argues that her attorney in the instant matter, Bradley Edwards (through his attorney Jack Scarola) contacted Prof. Dershowitz to seek his voluntary cooperation in answering questions about Prof. Dershowitz’s client, Jeffrey Epstein’s conduct. Prof

atter, Bradley Edwards (through his attorney Jack Scarola) contacted Prof. Dershowitz to seek his voluntary

by using the Florida Courts eFiling Portal and thus served by electronic mail: [email protected], [email protected], [email protected] to: Jack Scarola, Esq, Searcy Denney Scarola Barnhart & Shipley, P.A., Counsel for Plaintiff, 2139 Palm Beach Lakes Blvd., West Palm Beach, Florida 33409; jonijones@

the Court need look no further than Dershowitz’s counterclaim in this case. Count I of Dershowitz’s Counterclaim (styled as “False Allegations in the Joinder Motion”) contends that Edwards and Cassell should pay him damages because they “filed a pleading in the Federal Action titled ‘Jane Doe #3 and Jane D

rshowitz Case No.: CACE 15-000072 Edwards and Cassells Response to Dershowitz's Motion to Determine Confidentiality of Court Records Page 12 of 20 Scarola) and Dershowitz’s extended answer are quoted in full— including Dershowitz’s reference to the oral sex allegation that he now argues this Court shoul