Epstein Secrets

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

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

TA00808600 Edwards adv. Epstein Case No. 502009CA040800)OOCXMBAG Response in Opposition to Epstein's Motion to Amend Exhibit List. COUNSEL LIST Scott J. Link, Esq. Kara Rockenbach, E Link & Rockenbach, 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Pho Faxral. Attorneys for Jef

-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

icial Administration 2.516(b)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 [fax] By: Is/ Scott J. Link (FBN Kara Berard Rockenbach (FBN Primary: Primary: Secondary: Secondary: Counsel for Counter-Defendant Jeffrey Epstein 9 EFTA00808712 SERVI

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

ember 9, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA By: /s/ Scott J. Link (FBN Kara Berard Rockenbach (FBN Primary Primary Second Second Counsel for Counter-Defendant Jeffrey Epstein 20 EFTA00794296 SERVICE LIST

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

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

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