Epstein Secrets

dro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 ch, FL 33401 Jack Scarola, Esq. Jack P. Hill, Esq. Scatty Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for Plaintiff, Counsel for Plaintiff in Related Case No. 08- 80469 Robe

01h Avenue North Suite 404 Lake Worth, FL 33461 Fax: Counsel for Plaintiff in Related Case No. 08- 80811 Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Fax: ounse Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Bo

EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated

Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel fir Dejåulant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal

nded Counterclaim and November 29, 2011, Second Amended Counterclaim, he characterized it as a "highly defamatory press release." (D.E. 388, ¶ 13) (D.E. 413, ¶ 9). • January 6, 2012: In Answers to Interrogatories, Edwards stated that: "Bradley Edwards has described the special damages he has susta

nd correct copy of the foregoing was sent via e-mail and U.S. Mail on this 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, 250 Australian Ave. South,

asked solely to poison the wel1.6 The Court recently sustained Plaintiffs objections to discovery requests geared solely to alleged sexual activity (D.E. 148, 149, and 150). Accordingly, the sword and shield doctrine does not apply to the illegitimate and irrelevant questions which Plaintiff declined

Edwards' expert's report was disclosed. 4 EFTA00808424 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-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Philip M. Burlington

y, probable cause and Edwards' professional reputation. BACKGROUND I. Pursuant to this Court's July 20, 2017, Order Specially Setting Jury Trial (D.E. 938), the disclosure of experts retained to formulate an expert opinion was due 60 days prior to trial. At that time, trial was set on December 5,

Respectfully submitted, , respectfully requests that /s/.lack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. Phone: Fax: Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 20th, 2009, I electronically filed the foreg

11-MARRA/JOHNSON Plaintiff, v. SS EPSTEIN and Defendants. PLAINTIFF, RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR CONTINUANCE OF TRIAL (D.E. 150) Plaintiff, by and through her undersigned counsel, hereby files her Response to Defendant, Jeffrey Epstein's, Motion for Continuance of Trial

orporated Memorandum of Law. Respectfully submitted, /.s/lack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. West Palm Beach, Florida 33409 Attorneys for Plaintiff EFTA00201233 Case 9:08-cv-80811-KAM Document 64 Entered on FLSD Docket 04/24/2009

he arguments raised in Plaintiffs Response In Opposition to Defendant's Motion to Stay Complaint in Jane Doe No.1 v. Epstein (Case No. 08-CV-80893, D.E. 31)(Attached hereto as Exhibit "1") and Plaintiffs Memorandum in Opposition to Motion to Stay and or Continue Action in Jane Doe No. 2 v. Epstein (

o all counsel of record on the attached service list. /s/Jack P Hill Jack Scarola Florida Bar No.: 169440 Jack P. Hill Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Attorneys for Plaintiff 6 EFTA00201398 Case 9:08-cv-80811-KAM Document 1

EPSTEIN upon her, Plaintiff intends to rely exclusively on the statutory damages, rather than those damages which are available at common law. (See D.E. 113). If however, the Court rules that the statutory floor applies only one time, regardless of the number of times EPSTEIN committed an enumerated

sel for Counter-Defendant Jeffrey Epstein 9 EFTA00794306 SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 [email protected] [email protected] [email protected] scarolateamasearcylaw

ey." D.E. 1318 04/03/18 Edwards' Motion for Sanctions for Violation of Court Order (withdrawn) — quoting Epstein's statements: 6 EFTA00794303 D.E. I Date I Document ¶ 12 - "Second, the alleged eight-year-old "confidential" information to which Edwards refers is 47 exhibits comprised of a s

Trial and Scheduling Order. Respectfully submitted, /.s/Jack P Hill JACK SCAROLA Florida Bar No. 169440 JACK P. HILL Florida Bar No.: 0547808 Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 8th, 2009, I electronic

extended. In light of Plaintiff's filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to

on to Modify Trial and Scheduling Order. Respectfully submitted, /.s/.lack P Hill JACK SCARO Florida Bar NolMil JACK P. HILL Florida Bar No.: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach. 09 Phone: Fax: Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on

s extended. In light of Plaintiffs filing of her Conditional Notice of Intent to Exclusively Rely on Statutory Damages Provided by 18 U.S.C. §2255 (D.E. 113) on June 5, 2009, Plaintiff agrees to a modification of the pretrial schedule as outlined in Defendant EPSTEIN's Motion to Strike (D.E. 104); to