Epstein Secrets

of each billing statement. Any portions of such deposits that ultimately are not used for expenses or applied to fees will be refunded. (By rule of the Supreme Court of Florida, the interest generated on such funds is remitted by the bank to the 5019-009.engmtmcm.02 EFTA00795578 ENGAGEMENT MEMORANDUM TO: Gunster

. 561.598.6800 Fax 561.598.6801 www.culversmithlaw.com D. Culver Smith Ill ceu 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Th

ng factual and legal support for the opinions to which I may testify and in defining 5019-009.cngmtmcm.02 EFTA00795577 ENGAGEMENT MEMORANDUM TO: Gunster, Yoakley & Stewart, P.A. RE: Epstein v. Rothstein November 2, 2017 Page 2 of 5 potential areas for inquiry. My testimony will be as an objective

R. SCAROLA: Your Honor, the next issue It So based upon those two very fundUnantal IS before the Court relates co the plaintiff's II principles, the U.S. Supreme Court recognition, the 19 entitlement to an adverse inference instruction 10 Fifth Anentrient protections do not apply in the 20 arising out of each

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

R. SCAROLA: Your Honor, the next issue It So based upon those two very fundUnantal IS before the Court relates co the plaintiff's II principles, the U.S. Supreme Court recognition, the 19 entitlement to an adverse inference instruction 10 Fifth Anentrient protections do not apply in the 20 arising out of each

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

stantive filings in this case until June 2017, after the Supreme Court declined jurisdiction. Defendant noticed this matter for trial shortly before the Supreme Court's decision and, in July 2017, the Court entered its trial order, special setting a ten-day trial less than five months away. INTRODUCTION The trial

er 13, 2017, Plaintiff retained new trial counsel, who appeared in the case on November I, 2017. Plaintiff also retained a team of lawyers from the Gunster law firm as trial support. None of the things Plaintiff is asking for in this Motion is based on lack of manpower. Even using all of these resources