Epstein Secrets

16 17 18 19 20 21 22 23 24 25 of the files during the operative period of Adler's and Rothstein's dealings, allegedly, as it relates to Adler, clearly as it relates to Rothstein by his own testimony as to appease these investors and to further his own Ponzi scheme. Again, this is by no

A00788321 211 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of the files during the operative period of Adler's and Rothstein's dealings, allegedly, as it relates to Adler, clearly as it relates to Rothstein by his own testimony as to appease these investo

we get an answer on the record as to whether that is going to happen so I know whether this is discovery that I need to proceed with. THE COURT: Binger has long held, essentially, that there's really no difference from the discovery standpoint between rebuttal witnesses or rebuttal evidence and d

addad an) John Scarola irsETPH \CKERMAN JR Maria Kelchian ~la) Matthew D Weissing II~M) Pi 4IMP M RUM INC- roN [email protected] Russell S, Adler (~Iffil= Tonja Haddad Coleman1.a.) William Bennett King Ma) William Chester Brewer, Jr. I William B. King a) John Scarola ~Ma Rodney G Romano Il

-over" so that, rather than appear as trial counsel on the eve of trial to actually try the case, they can reopen discovery and start from scratch. Binger, however, does not permit Epstein to do so. Epstein correctly notes that the Court should not permit Epstein to amend his exhibit list if the propo

Complaint, which includes the following allegations: Attorney Scott Rothstein aided by other lawyers . . . at the firm of Rothstein, Rosenfeldt and Adler, 5., for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to

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

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

days ago, and discussed perhaps within the last few 23 as part of a cannon interest privilege with an 23 weeks, then we would have essentially a Binger 24 express representation it was attorneys' eyes only, 24 issue to analyze. So Hiss Rockentoch, go ahead and 25 with an express representation

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

days ago, and discussed perhaps within the last few 23 as part of a cannon interest privilege with an 23 weeks, then we would have essentially a Binger 24 express representation it was attorneys' eyes only, 24 issue to analyze. So Hiss Rockentoch, go ahead and 25 with an express representation

language is imprecise, but what I am trying to point out is that these emails are part of the emails that originated on the Rothstein, Rosenfeldt, Adler servers. They were, that electronic data, was transferred to compact disks. The compact disks were used to print out emails, including those that

tion -- THE COURT: That's what I'm doing today until the noon hour. MR. LINK: Great. Thank you, Your Honor. MR. SCAROLA: And there is a threshold Binger issue, which my presentation addresses that I provided to opposing counsel but have not yet given to Your Honor. I can give it to Your Honor now,