Epstein Secrets

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 Rachel J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 E

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 [fax] By: /s/ Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Angela M. Many (FBN 26680) Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Co

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax] By: Is___ l Scott J. Link (FBN Kara Berard Rockenbach (FBN Angela M. Many (FBN Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendan

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

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 (FBN Kara Berard Rockenbach (FBN Angela M. Many (FBN Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendan

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

H, 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 BN Angela M. Man (FBN Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter