Epstein Secrets

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00799400 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

t Edwards and Cassell made in this other lawsuit are somehow 2 binding on Ms. Edwards and Cassell had separate legal 3 counsel, Florida attorney Jack Scarola. Whatever was going on 4 in that case isn't binding on Ms. 5 Under the relevant rules, an attorney's statements are 6 binding on a client only

separate legal 3 counsel, Florida attorney Jack Scarola. Whatever was going on 4 in that case isn't bin

which only 3 further substantiates Ms. testimony that at one point 4 she attempted to get away from defendant's abuse, along with -- 5 and Mr. Figueroa testified to the same. 6 So again, I would also reiterate that her reputation 7 as a child for being a truant or a runaway is not what is at 8

that Edwards and Cassell made in this other lawsuit are somehow binding on Ms. . Edwards and Cassell had separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't binding on Ms. 5 Under the relevant rules, an attorney's statements are 6 binding on a client only on

ad separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't bindin

th, 2002, which only further substantiates Ms. testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in

Edwards and Cassell made in this other lawsuit are somehow binding on Ms. Giuffre. Edwards and Cassell had separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't binding on Ms. Giuffre. Under the relevant rules, an attorney's statements are binding on a client only o

had separate legal counsel, Florida attorney Jack Scarola. Whatever was going on in that case isn't binding

which only further substantiates Ms. Giuffre's testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in t

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585371 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

neys for Epstein 20 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585392 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldbe er, Es . • Atterbury, Goldberger, & Weiss,

RVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Es . Searcy Denney Scarola et al. 2139 Palm Be

ng party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel