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

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

rs prior to the Court's deadline to disclose trial exhibits: (1) Exhibits from production in this case; (2) Public records related to El., 1., and Jane Doe; (3) Public records related to a 2015 case involving Edwards and Alan Dershowitz; (4) Publicly available information regarding Edwards on his law fi

-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

efore the renewed motion should be denied. A. The "Legal Ethics and 1 .sponsibility" Related to the Discovery Edwards Conducted in the El M. and Jane Doe Cases Has Been at Issue Since 2009. 3. The first category of Smith's proposed expert testimony is "legal ethics and responsibility," regarding th

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

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

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

RE II Deoksbor 5th and nide it clear to all parties that 10 12 exhibits that. here net disclosed by the end of II For Non-Parties L.M., E.M. 4 Jana Doe 22 1a Deoabor -- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were no

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

question in front of you sight now is • very brief, representing three victims; LH, EM and • what to do about this. Well, we knee one thing. • Jane Doe. /Vat ono housekeeping natter. s lie know there's been absolutely no waiver of 10 No have riled a notion to intervene, which is 10 attorney/cl

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

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

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

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.

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

oulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe HATCH, JAMES 4 DODGE, P.C. 10 Nest Broadway, Suite 400 Salt Lake City, UT 84101 By PAUL G. CASSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBUR

your paralegal' • by an unsuccessful notion in limlne. Furthernare, 5 /12. ROCWITEACH: Who obtained the three boxes. prejudice in the context of Binger refers to the 4 the three taxes free Fowler White, which contair. surprise in fact of the objecting party and is not 7 that CD which la at Issue