Epstein Secrets

icial Administration 2.516(b)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 [fax] By: /s/ Scott J. Link Kara Berard Iteet. ac Angela M. Man Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Eps

nded Counterclaim and November 29, 2011, Second Amended Counterclaim, he characterized it as a "highly defamatory press release." (D.E. 388, ¶ 13) (D.E. 413, ¶ 9). • January 6, 2012: In Answers to Interrogatories, Edwards stated that: "Bradley Edwards has described the special damages he has susta

1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax] By: Is Scott J. Link (FBN Kara Berard Rockenbach Rachel J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/C

y, probable cause and Edwards' professional reputation. BACKGROUND I. Pursuant to this Court's July 20, 2017, Order Specially Setting Jury Trial (D.E. 938), the disclosure of experts retained to formulate an expert opinion was due 60 days prior to trial. At that time, trial was set on December 5,

requests to be excused from personally attending the Show Cause hearing. Epstein will be represented at the hearing by his counsel, Chad Pugatch and Scott J. Link. ARGUMENT A. What Happened to the Disc in 2018 is Not a Violation of This Court's November 2010 Agreed Order. The Court was clear that issues re

the issue of his knowledge and possession of the disc. (Apr. Tr. 36:2-9.) The Show Cause Order also provided for the filing of sworn declarations. (D.E. 6366,91 5 i.v.) Specifically, it provides: Unless otherwise ordered, the direct testimony of each witness, except adverse, hostile or rebuttal witn

t the upcoming October 26, 2018, evidentiary hearing, and to strike irrelevant, scandalous and impertinent questions asked during the deposition of Scott J. Link, acting as corporate representative of the law firm Link & Rockenbach, PA ("Link & Rockenbach"), which occurred on October 13, 2018. Due to the imp

uly 20, July 25 and September 26, 2018, Edwards filed Notices of Taking Link & Rockenbach's deposition duces tecum. (D.E. 6390; D.E. 6391; D.E. MOO; D.E. 6406; D.E. 6468.) Epstein filed his Responses and Objections on July 20 and October 4, 2018. (D.E. 6402; 6478.) In his Response, Epstein objected t

vice List below on November 14, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). SIM By: Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903 Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00794306 SERVICE LIST Jack Scarola Karen E

ey." D.E. 1318 04/03/18 Edwards' Motion for Sanctions for Violation of Court Order (withdrawn) — quoting Epstein's statements: 6 EFTA00794303 D.E. I Date I Document ¶ 12 - "Second, the alleged eight-year-old "confidential" information to which Edwards refers is 47 exhibits comprised of a s