Epstein Secrets

ant/Counter-Plaintfff Bradley J. Edwards Bradley J. Edwards Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Ed

ealing with an expert which is otherwise qualified to testify to what he's going to testify. (3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which should pertain in only

ley J. Edwards Link & Rockenbach, 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Marc S. Nurik, Es uire One E Broward Blvd., Suite 700 10 EFTA00808618 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstei

s follows: &nicer Does Not Permit a Party to Ignore Trial Court Orders In this and other motions, Epstein relies on the Supreme Court's decision in Binger to argue that Epstein should be permitted to ignore this Court's pre-trial orders, as long as there is no prejudice to Edwards. This interpretation

dwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 Counsel for Defendant Scott Rothstein Jack A. Goldberge

EARING After ruling that Epstein would not be allowed to use certain exhibits identified since March 2018 on his Clerk's Trial Exhibit List under a Binger' analysis, this Court raised the pending issue of the 47 e-mails that Edwards claims are privileged and Epstein's pending request for an in camera

ndant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Edwards Pottin er LLC Co-Counsel for Defendant/Counter-Plaint& Bradley J. Edwards Marc S. Nurik Law Offices of Marc S. Nurik Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterb , Goldber er & Weiss, P.A. o- ounse or aint:I oimt

hibit 3.) During its in camera review, this Court must consider and determine: 1. The e-mails are directly relevant to the issues for trial and no Binger's "surprise in fact" exists regarding them; 2. If any work product protection existed, it was waived or excepted based on: a. Farmer Jaffe's exp

LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 [email protected] Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 [email protected] Counsel for Defendant Scott Rothstei

EARING After ruling that Epstein would not be allowed to use certain exhibits identified since March 2018 on his Clerk's Trial Exhibit List under a Binger' analysis, this Court raised the pending issue of the 47 e-mails that Edwards claims are privileged and Epstein's pending request for an in camera