Epstein Secrets

GOLDBERGER a WEISS. P.A. e 1400 Iv would be unacceptable, that specific individual 17 lo exhibits needed to be listed. I'n sure your Honor By JACK A. GOLDBERGER, ESQUIRE :5 has a recollection of these circumstances. And 18 29 21 that, obviously, is a fairly standard order that S0 31 your Honor adheres

fling 17 Mr. Link's law flat, the Fowler Mite law firm, I 17 that request on behalf of my clients. is is believe there are several others, Mr. Goldterger's law firm, we want then all co canvass their 1$ 19 We're told that Mr. Goldberger has seen it, we're told Mr. Epstein ha0 seen it. We want to

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

4 1a disclosed would net be penn/Lted CO be used at. 25 For Jeffrey Epstein: 17 trial. You rude it clear that catchall listings 16 ATTERBURY, GOLDBERGER a WEISS, P.A. 1ca would be unacceptable; that specific Individual 17 lo exhibits needed to be listed. I'n sure your Honor By JACK A. GOLDBERGER

ERBURY, GOLDBERGER a WEISS, P.A. 1ca would be unacceptable; that specific Individual 17 lo exhibits needed to be listed. I'n sure your Honor By JACK A. GOLDBERGER, ESQUIRE 25 has a recollection of these circumstances. And 10 29 21 that, obviously, is a fairly standard order that S0 31 your Honor adhere

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

SSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBURY, GOLDBERGER 4 WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOLDBERGER, ESQUIRE 1 2 3 S 6 9 10 11 12 13 14 15 16 17 la 19 20 it 22 22 24 25 exhibit list filed by Mr. Epstein on November 16. 2017. T

nt. My law : . . . • documents, the appellate court will have the opportunity to do that. is 25 and My client. And 1 tan say legal counsel, Mr. Goldberger. So that's it. THE COURT: So you're suggesting to file with :a MR. SCAROLA: that nay require 40114 further • the Clerk or Court under seal the d

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

s Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, . 250 Australia

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

y Epstein Jack A. Goldber er, Es uire Atterbury Goldberger & Weiss, 250 Australian Avenue S, Suite 1400 We

-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

01 Pho i0 Fax: Jack A. Esquire jg Atterbury Goldberger & Weiss, . 250 Australian Avenue S, Suite 1400

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

01 Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australia

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

k Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterb , Goldber er & Weiss, P.A. o- ounse or

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

m Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Austral

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

d of advice of counsel defense. THE COURT: Would you tell me who those attorneys are, please? MR. SCAROLA: Mr. Roy Black is one, and I think Mr. Goldberger was another. MR. GOLDBERGER: Yes, Mr. Goldberger is one of them. Mr. Critton is one and Mr. Akerman. MR. SCAROLA: Mr. Critton and Palm Beach Rep

we get an answer on the record as to whether that is going to happen so I know whether this is discovery that I need to proceed with. THE COURT: Binger has long held, essentially, that there's really no difference from the discovery standpoint between rebuttal witnesses or rebuttal evidence and d