Epstein Secrets

ell 383 S. University Salt Lake City, UT 84112-0730 [email protected] Limited Intervenor Co-Counsel fora., E. It". and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel forM., E.W. and Jane Doe 5 EFTA00808425

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

ffrey Epstein Paul Cassell 383 S. University St. Salt Lake City, UT 84112-0730 Limited Intervenor a -Counsel for E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor a -Counsel for n, E.W. and Jane Doe 10 EFTA00808713 EXHIBIT B Epstein'

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

terb , Goldber er & Weiss, P.A. o- ounse or aint:I oimter- e endant Je E•stein unite ntervenor o- ounse or L.M., E.W. and Jane Doe Jay Howell Jay Howell & Associates L.M., E.W. Limited Intervenor Co-Counsel for and Jane Doe 21 EFTA00794297

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

383 S. University St. Salt Lake City, UT 84112-0730 cassellpalaw.utah.edu Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 iay(ajavhowell.com Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe 10 EFTA0079430

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