Epstein Secrets

ue, Suite 2 yard, Suite 700 33301-3268 301 Co-Counsel for Defendant/Counter-Plaintiff Counsel for Defendant Scott Rothstein Bradley J. Edwards Jack A. Goldberger 4 - to op .. - . . eiss, P.A. Paul Cassell Suite 1400 0730 ' II Limited Intervenor Co-Counsel for LM., E.W. and Jane Doe o- ounse or • ain

ents from the disc that Edwards has asserted privilege claims over. • On March 8, 2018, Link & Rockenbach, PA notified its client, its co-counsel (Jack Goldberger), its litigation team working on this matter, and its expert, Timothy Chinaris, to destroy all hard copies and electronic versions of the documents

dant Scott Rothstein Bradley J. Edwards Jack A. Goldberger 4 - to op .. - . . eiss, P.A. Paul Cassel

ndix in Support of Response in Opposition to Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence, and D.E. 1252, Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for 2 EFTA00793756 Additional Limited Discovery, Evidentiary Hearing and

Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Marc S. Nurik Law Offices of Marc S. Nurik Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbur , Goldber . er & Weiss, P.A. - Paul Cassell Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintiff/Counter

k Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbur , Goldber . er & Weiss, P.A. - Paul C

s Permission to Alter Trial Evidence by Replacing Names with Initials of Edwards' Three Clients on Trial Exhibits [D.E. 1240] 15 3/5/18 Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special Ma

; send draft to D. Indyke for review; work on Notice re J. Epstein's trial testimony; work on new dates for J. Epstein's deposition; follow up with J. Goldberger, D. Indyke and C. Pugatch re proposed new dates EFTA00799184 Client Ref: 0002 - 0001 Invoice # 1034 Date Services 07/11/18 SJL Telephone co

SJL Work on bankruptcy opening statement; work on Declaration of S. Link; work on Declaration of .1 Epstein; telephone conference with J. Epstein, J. Goldberger and D. Indyke; work on arguments for upcoming hearing; review multiple Responses filed by B. Edwards and follow up with client and D. Indyke re sa

e J. Epstein's Untimely Supplemental Exhibits and to Strike All Exhibits and Reference to Documents Containing Privileged Materials, and Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, for purposes of drafting Sworn Declaration of Fact of Scott J. Link, as part of Bankr

SJL Work on bankruptcy opening statement; work on Declaration of S. Link; work on Declaration of J. Epstein; telephone conference with J. Epstein, J. Goldberger and D. Indyke; work on arguments for upcoming hearing; review multiple Responses filed by B. Edwards and follow up with client and D. Indyke re sa

; send draft to D. Indyke for review; work on Notice re J. Epstein's trial testimony; work on new dates for J. Epstein's deposition; follow up with J. Goldberger, D. Indyke and C. Pugatch re proposed new dates EFTA00799205 Client Ref: 0002 - 0001 Invoice # 1034 Date Services 07/11/18 SJL Telephone co

e J. Epstein's Untimely Supplemental Exhibits and to Strike All Exhibits and Reference to Documents Containing Privileged Materials, and Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, for purposes of drafting Sworn Declaration of Fact of Scott J. Link, as part of Bankr

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

F HIS SUPPLEMENT TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS, ETC. As supplemental authority in support of his Motion for Court to Declare Relevance and Non- Privileged Nature of Documents and with Specific Request for In Camera Review to Determine Relevance, Inapplicability

lephone conferences and communications with D. Indyke and J. Epstein re same; follow up on hearing schedule; trial team meeting with J. Goldberger, M. Goldberger, J. Caldwell, T. Campbell, R. Glasser and K. Rockenbach re trial work, hearing preparations and strategies; work on objections to B. Edwards' depo

from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440; work on Response to B. Edwards' Motion for Separate Trials; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special M