Epstein Secrets

nd 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

Jay Epstein Paul Cassell 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

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 the most compelling

Link & Rockenbach reviewed were quite clearly not attorney-client privileged communications between Edwards and his three tort clients (M., E.W. or Jane Doe). Most significantly, numerous e-mails it reviewed were devastating to Edwards' case and contradicted both his sworn testimony and statements his co

l by way of memorandum, and that will be done under seal and will continue to be under seal, and will be filed under seal in case of Ringer v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2 EFTA00808705 a need for appellate review. So that is going to be the direction of the Court, that the motion be

in reliance on Edwards' previous waiver and agreement to produce the same, these e-mails must be deemed not protected by Edwards' clear waiver. See Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-product privilege with respect to docum

Link & Rockenbach, PA discovered documents that were voluntarily produced years ago by Edwards to his potential adversaries at the 6Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 3 EFTA00794279 time — the Razorback plaintiffs. These e-mails directly contradict Edwards' sworn testimony and pos

Epstein Paul Cassell 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.

that any substantive discussion of those emails will be done under seal by way of memorandum, and that will be done under seal and 'Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2Excerpts of the November 2, 2018, Hearing Transcript are attached as Exhibit A. 2 EFTA00794299 will continue to b