Epstein Secrets

ROLA: Q. Which lawyers? A. Burman Critton, Jack Goldberger, and a bunch of the others, sir. Id at 116; lin

ys prepare responses to wildly irrelevant discovery in various locations at a minimum, sir. BY MR. SCAROLA: Q. Which lawyers? A. Burman Critton, Jack Goldberger, and a bunch of the others, sir. Id at 116; lines 8-19. Q. I want as much information as you can give me about this element of damage which you c

her through a proper motion or at trial, so that this Court can properly examine the issue and rule on Edwards's request that it be precluded. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998); Aguila-Rojas v. City Management Group Corp., 606 So.2d 765, 766 (Fla. 3d DCA 1992). In the case

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

tein's Motion to Amend Exhibit List. McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) (citing Binger). As the Fourth DCA aptly stated in Tomlinson-McKenzie: The objecting party is prejudiced by the admission of such evidence if the party might have taken some action to protect itself had it had timely

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

n Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Renewed Motion for Leave to Disclose Expert Witness "expert" testimony. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) ("There was no finding that appellants failed to comply with the pretrial order in bad faith. Th