Epstein Secrets

Case 9:08-cv-80736-KAM Document 160 Entered on FLSD Docket 04/17/2012 Page 3 of 13 1 and Jane Doe 2. He and his own lawyer in a related state case, Jack Scarola, have been widely quoted by local and British press, making prejudicial and inflammatory statements about Mr. Epstein. If the correspondence betwee

nd inflammatory statements about Mr. Epstein. If the correspondence between the defense team and the government is not kept confidential, attorneys Scarola and Edwards could reasonably be expected to continue disseminating out-of-court publicity and making extrajudicial statements and commentary to the

yer skips over what is arguably the most important part of the In re Dean litigation as it pertains to the relief sought here: Following remand from the Fifth Circuit, the district court denied the motion of the victims to invalidate the defendant's plea agreement as a 6 EFTA00205547 Case 9:08-cv-80736-KAM Doc

vants claim that current counsel for Jeffrey Epstein in a pending state court case (Scott Link, Esq.) sent counsel for Bradley Edwards in that case (Jack Scarola, Esq.) a flash drive which purported to duplicate "the disc we located in Fowler White's files." DE 6326,1 24. Movants contend that the flash drive

to all registered users on the CM/ECF system, which includes counsel identified on the service list below. SERVICE LIST Jack Scarola Sears Denn , Scarola, Barnhart & Shipley, P.A. yard Counsel for Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for

3 In Bonner v. City of Prichard, 661 F.2d 1206 (I I th Cir.1981) (en banc), the Eleventh Circuit adopted as binding precedent all cases decided by the Fifth Circuit, prior to October I, 1981. 9 114428178.1 EFTA00793928 Case 09-34791-RBR Doc 6355 Filed 04/11/18 Page 10 of 17 adequately resolved by agreeme

1, 1 27. In her April 7, 2011 interview with Mr. Scarola, Jane Doe No. 3 stated that she was contacted in

specific issue of adding a new party, and whether Rule 15 or Rule 21 applies to the addition of a party under the Federal Rules of Civil Procedure, the Fifth Circuit resolved this issue in McLellan,. Mississippi Power & Light Co., 526 F.2d 870 (56' Cir.), vacated in part on other grounds 545 F.2d 919 (5th Cir. 1

11- 27. In her April 7, 2011 interview with Mr. Scarola, Jane Doe No. 3 stated that she was contacted in

specific issue of adding a new party, and whether Rule 15 or Rule 21 applies to the addition of a party under the Federal Rules of Civil Procedure, the Fifth Circuit resolved this issue in McLellan I. Mississippi Power & Light Co., 526 F.2d 870 (5th Cir.), vacated in part on other grounds 545 F.2d 919 (5th Cir.

1, r 27. In her April 7, 2011 interview with Mr. Scarola, Jane Doe No. 3 stated that she was contacted in

, which required leave of court. Since leave was not obtained by plaintiff, the district court dismissed the complaint as to the unions. On appeal, the Fifth Circuit posed the question: Which rule takes precedence if a party attempts to drop or add parties by an amended pleading filed before a responsive pleadin