Epstein Secrets

y of July, 2017. CIRCUIT *1:. Arl. c.it JUDGE DONALD HAFELE Circuit Judge Copies furnished to: F F

-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

n to Edwards' Most Pain Beach, Florida BEFORE: Donald Hafolo, Presiding Judge 1, Second Supplenental

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

n to Edwards' Most Pain Beach, Florida BEFORE: Donald Natal., Presiding Judge I, Second Supplenental

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

ation was completed. Additionally, The Honorable Donald W. Hafele's stated interest in first allowing the

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

ixie Highway, Room 200 Nest Palm Beach, Florida Donald Hafele, Presiding Judge This cause cane on to be

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

d cause came on for hearing before the Honorable Donald W. Hafele, Presiding Judge, at the Palm Beach Co

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,