Epstein Secrets

-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

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 Jeffrey Epstein Jack A. G

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

ou've done your job." (March 8, 2018, Aft. Tr. 59:1-4.)5 • "So I again want to make clear that I'm finding absolutely no fault with Mr. Link, Miss Rockenbach, Miss Campbell or anyone else from the Link and Rockenbach firm in terms of what they did, albeit in the manner in which they had to do it and the

tion -- THE COURT: That's what I'm doing today until the noon hour. MR. LINK: Great. Thank you, Your Honor. MR. SCAROLA: And there is a threshold Binger issue, which my presentation addresses that I provided to opposing counsel but have not yet given to Your Honor. I can give it to Your Honor now,

ip. We did not take exhibits and documents we intended to use and had it in our files, sit back and wait. This Court knows that's not the way Ms. Rockenbach and I practice, it's not the way we did it here. And we made sure that we produced, on a rolling basis, the documents, so as not to have them hit

bits create prejudice, they've known about them for months, they're in the public record, they're emails from Mr. Edwards himself and, Your Honor, Binger teaches us this: Yes, you have discretion. But the discretion is really driven by, as you said, process and fairness, and is there really a preju

te-filed exhibits, that most, if not all, of the proposed late-added exhibits were available to Mr. Epstein or his counsel before Mr. Link and Ms. Rockenbach. And they were available either before the previously scheduled December 17th trial date, or the date set earlier this year in March of 2018. I'v