August 15, 2011

August 15, 2011 Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, Florida 33409 Re: Edwards adv. Epstein Dear Mr. Scarola: As you may know, I was Jeffrey Epstein's attorney when he submitted his guilty plea. Accordingly, "any knowledge" I may have in connection with that plea is privileged information. If you would let me know what non-privileged information you would seek from me, I would then be able to decide whether to cooperate. Sincerely, Alan M. Dershowitz INT 000030393 PROT0 bee: JE INT_000030393 PROT1 August 29, 2011 Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, Florida 33409 Re: Edwards adv. Epstein Dear Mr. Scarola: I have never personally observed Jeffrey Epstein in the presence of underage females. I do not believe you have any reasonable basis for believing that I have. If you claim to have "reason to believe," please provide me with any such reason. I am certain I can demonstrate to you that it is false. Sincerely, Alan M. Dershowitz INT_000029702 PROT2 INT_000004155 From: Alan Dershowitz Sent: Monday. Janua To: Jack Scarola Subject: Fwd: Scarola Sent from my iPhone Begin forwarded message: > From: Carolyn Cohen Ma > Date: January 5, 2015 at 3:43:11 PM EST > To: Alan gmail > Subject: Scarola • Dear Mr. Scarola, • It is not true that your firm ever previously asked me to be deposed regarding the false charges of sexual assault against me since there were no such charges at the time of the request. I will happily agree to be deposed about these false charges as part of the defamation action I am bringing against Mr. Edwards, Mr. Cassell and Ms. Roberts I expect that they, too, will agree to be deposed. I am confident that mutual depositions will produce the truth-- namely that Edwards and Cassell unethically filed a false charge against me knowing it was untrue. • There are no other current legal proceedings to which we are all parties that would justify any depositions. PROT3 From: Jack Scarola [JSX& Sent: Monday, January 05,2015 4:59 PM To: Alan Dershowitz Subject: Re: Scarola Dear Mr. Dershowitz: It will be unproductive to debate by email either past history regarding our efforts to depose you, the merits of your unfiled public relations "defamation action", or your unusual position that you need to be a party to a pending proceeding in order to be deposed. Allow me to simply note that you are wrong on all counts. If you have, in fact, retained counsel to address issues relating to either Mr. Edwards or Professor Cassell, and assuming you are not intending to appear as co-counsel on your own behalf, then please forward this exchange to your lawyer and direct future communications through him/her. Sincerely, Jack Scarola, Esq. On Jan 5, 2015, at 3:55 PM, "Alan Dershowitz" > wrote: Sent from my iPhone Begin forwarded message: From: Carolyn Cohen < Date: January 5, 2015 at 3:43:11 PM EST To: Alan gmail < Subject: Scarola Dear Mr. Scarola, It is not true that your firm ever previously asked me to be deposed regarding the false charges of sexual assault against me since there were no such charges at the time of the request. I will happily agree to be deposed about these false charges as part of the defamation action I am bringing against Mr. Edwards, Mr. Cassell and Ms. Roberts I expect that they, too, will agree to be deposed. I am confident that mutual depositions will produce the truth-- namely that Edwards and Cassell unethically filed a false charge against me knowing it was untrue. There are no other current legal proceedings to which we are all parties that would justify any depositions. Privileged and Confidential Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 PROT9. 52510-2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at and INT_000004156 PROT4 destroy all copies of the original message. Thank you. INT 000004156 PROT5 From: Sarah Neel on behalf of Alan Dershowitz Sent: uesday, January 1 15 1:31 PM To: Alan Dershowitz Subject: FW: Epstein - Deposition of Alan Dershowitz on October 28. 2009 Is From: Jacquie Johnson [mailto: Sent: Wednesday, October 21, 2009 11:52 AM To: Sarah Neely Subject: Epstein - Deposition of Alan Dershowitz on October 28, 2009 Hi Sara - Mr. Dershowitz has been served with a Subpoena for Deposition for the 28th. We have a number of attorneys travelling from South Florida for the deposition and before I make travel arrangements, can I confirm with you that the depo is confirmed. Jacquie Johnson Legal Assistant to Brad Edwards, Esq. Partner Rothstein Rosenfeldt Adler 401 East Las Olas Blvd. Suite 1650 Fort Lauderdale. FL 33301 Telephone Fax mailto INT_000003829 PROT6 From: Sarah Neel on behalf of Alan Dershowitz Sent: Tuesday, January 13, 2015 1:34 PM To: Alan Dershowitz Subject: FW: Edwards adv. Epstein: Letter from Jack Scarola, Esq. to Alan Dershowitz, Esq. 9/7/11 Attachments: ATT17050815.gif; ATT17050816.gif: Scanned File.PDF From: Alan Dershowitz [mailto: Sent: Wednesday, September 07, 2011 8:52 PM To: Jeffrey Epstein Subject: Fw: Edwards adv. Epstein: Letter from Jack Scarola, Esq. to Alan Dershowitz, Esq. 9/7/11 Sent from my Verizon Wireless BlackBerry From: "Mary E. Pirrotta" < Date: Wed 7 Se 2011 15:49:15 -0400 To: < ailto: Subject: Edwards adv. Epstein: Letter from Jack Scarola, Esq. to Alan Dershowitz, Esq. 9/7/11 Copitrak Scan Notification [cid:copitrakhdr] Your Scanned File is Attached [cid:box] This e-mail message is privileged, confidential and subject to copyright. Any unauthorized use or disclosure is prohibited. Privileged and Confidential E-mail is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 PROT10. 52510-2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at and destroy all copies of the original message. Thank you. INT 000003837 PROT7 WES3LEALM BEACI1OFFIEE; 2139 PALM BEACH I ARES MVO WEST PALM READ H, Fl ORIDA 33409 P.O HO% 3626 WEST PALM REAM FLORIDA 33402 I M pa flash AITORsitys AT LAW 0.3SALwi SIA RAKER-BARRIS F. 0.1600Re OARNKART 7 HAMER BASS. le LAURIE J 860309 tam A. pinny ORISDA S RamER ALARLANOGARcR JAWS WARISTAIS016 JR. AOC P HAL DAM K. lattLY. WARIAI B. MO' DARRYL L LEWIS' Anima A NOR Tope RAMO( E Ouradoe roraRov TECO 'JOHN SURMA 1CHRISTIMI D. SEARCY •JOHlt &SHIPLEY el alitatorlicEl C SPUD ^ BRIAN P. Stunma7 main t WM C. CALVIN WARRINER 1203:5M. -GALL Depotexas sHARoloweRs ' Ramo cnonu &same= IRXRCKY mom( ALAR6tAno FAASSACRuSETIS MSSASSIPPI O k6w 14119571 RE 'NEW JERSEY • VIRcaNIA ▪ vaSsitallCel OC ARRAterams: vivw7 AtARTEJERA ROAM M. OUTRESHE OR/ROW OiLmORE Kim tROnlatiS Owls Li.RiNZNEZ 041/ORAR it town VriCENI L LECOUSO - R mats PETER LOW 005ERT W. pacium 77ARR P RCACV KATHRIEN SiA07 nye BMWs RONNE S 5IAPX voLTER A. STEM SEARCY DENNEY SCAROLA BARNHART et-SHIPLEYA VIA EMAIL AND U.S. MAIL September 7, 2011 Alan M. Dershowitz, Esquire Hauser Hall 520 1575 Massachusetts Avenue Cambridge, MA 02138 Re: Edwards adv. Epstein Our File No.: 291874 Dear Mr. Dershowitz: CIA LLAH Mow! (IffIrt THE TOWLE ICU& SIT NORTH CALHOUN STREET TN I AHASSFE. R 32301.1L11 PO.DOX 1220 TALLAHASSEE, FLORIDA 32502 While we are certainly under no obligation to disclose either the basis for our wanting to depose you or the subject matter of our intended inquiry, we are willing to respond to your request as a matter of professional courtesy. Multiple individuals have placed you in the presence of Jeffrey Epstein on multiple occasions and in various locations when Jeffrey Epstein was in the company of underage females subsequently identified as victims of Mr. Epstein's criminal molestations. This information is derived from both sworn testimony and private interviews. Your personal observations regarding such circumstances would clearly not involve any privileged communications, and it is those observations that will be the primary focus of our questioning. Please let us know when and where you will be available. Sincerely, Dictated But Not Signed By Jack Scarola To Expedite Delivery JACK SCAROLA JS/mep cc: Bradley J. Edwards, Esquire AsS,seiesta WWW.SEARCYLAW.COM INT_000003837_0001 PROT8