Epstein Secrets

STOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for

fer facts to a jury, statements to a jury, that they are going to be then arguing are credible, and so we have this joinder motion, drafted by Mr. Edwards and Mr. Cassell, that they would like to introduce into evidence, whole cloth into evidence, that contains the legal arguments and the statements o

there's an additional argument from counsel. It was their motion, so if it is, then -- THE COURT: Yes. Okay. MR. EDWARDS: And by the way, this is Brad Edwards on behalf of Ms. but I believe it's their up. MS. MENNINGER: Your Honor, a couple more points. They are related to what was just articulated for

0 21 22 23 24 25 number of what I deem to be improper vouching. THE COURT: Let's get to the supplemental reports. I've read the papers on the Daubert aspect and I have some familiarity with the report, but let's get to the supplemental. MR. PAGLIUCA: I will, your Honor. And I start there because

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

Y EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs. 10 THE COURT: Yes. My understanding as I left / 11 Was going to be Edwards' Second Supplement to TRANSCRIPT OF PROCEEDINGS 12 Motion in Lunine Addressing Scope of Admissible I) Evidence, and of course in that same vein

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

iled by 14 character are imodiately lepOred. IS Mr. Link to talk about his seeking a Frye or 15 This is civil. In civil it revive➢ damage➢ If Daubert analysis. 16 proximately caused. And it'➢ not a Frye analysis, 17 MR. BURLINGTON: Correct. That's my reading 17 it'➢ not a Daubert analy➢i➢, it

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

last wok just 4 and Any Reference to Docunenta Containing 4 So my suggestion to your Honor is that wo deal 5 Privileged Materials, Listed on Edwards' Privilege o first with the procedural issue because, as I said, 4 Log. 4 that will narrow issue. significantly. And then / MR. SCAROER: Yes,

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

iled by 14 character are imodiately lepOred. IS Mr. Link to talk about his seeking a Frye or 15 This is civil. In civil it revive➢ damage➢ If Daubert analysis. 16 proximately caused. And it'➢ not a Frye analysis, 17 MR. BURLINGTON: Correct. That's my reading 17 it'➢ not a Daubert analy➢i➢, it

, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys

to 2 a jury, statements to a jury, that they are going to be then 3 arguing are credible, and so we have this joinder motion, 4 drafted by Mr. Edwards and Mr. Cassell, that they would like to 5 introduce into evidence, whole cloth into evidence, that 6 contains the legal arguments and the statem

tional 19 argument from counsel. It was their motion, so if it is, 20 then -- 21 THE COURT: Yes. Okay. 22 MR. EDWARDS: And by the way, this is Brad Edwards on 23 behalf of Ms. but I believe it's their up. 24 MS. MENNINGER: Your Honor, a couple more points. 25 They are related to what was just arti

5 H3ulgiva 1 number of what I deem to be improper vouching. 2 THE COURT: Let's get to the supplemental reports. 3 I've read the papers on the Daubert aspect and I have some 4 familiarity with the report, but let's get to the supplemental. 5 MR. PAGLIUCA: I will, your Honor. And I start there 6

ed June 21, 2023. I declare under penalty of perjury that the foregoing is true and correct. Dated: June 22, 2023 Respectfully Submitted, By: Zs/ Bradley J. Edwards David Boies Boies Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 Telephone: (212) 446-2300 Facsimile: (212) 446-2350 Email: dboies@bs

estify, I could and would testify competently to the following facts. 3. The two law firms representing Plaintiffs, Boies Schiller Flexner LLP and Edwards Henderson Lehrman (collectively, "Class Counsel"), have invested significant resources into investigating and litigating this case and as such, hav

Daubed motion seeking to exclude expert testimony. On June 12, the Court granted the Class's motion for class certification and denied Defendant's Daubert motion as moot. Also in May 2023, the Parties agreed to engage in mediation. On May 30, 2023, the Settling Parties participated in a confidential m

d to dismiss both the initial and amended complaint, resisted discovery, took extensive discovery itself of the Plaintiff and our witnesses, filed a Daubert motion, and opposed class certification. B. Relevant Firm Experience 12. BSF has a strong record of successfully and diligently representing plai

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Plaintiff, B

e 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 of Binger is wrong and is an affront to the authority of a trial court to control its docket. Epstein has already tried, once,

in one or more rebuttal experts, assuming Epstein would be able to overcome multiple legal challenges to the admissibility of Mr. Smith's opinions. Daubert/Fabre challenges are likely. Admissibility hinges on the extent to which legal opinions invade the province of the Court to decide probable cause a

cial effect. See Zackson, 12 F.3d at 1182. If requested, such evidence must be admitted with limiting instructions to the jury. See United States v. Edwards, 342 F.3d 168, 176 (2d Cir. 2003). The Second Circuit "ha[s] adopted an inclusionary approach to evaluating Rule 404(b) evidence, which allows evid

e Government has given notice of a qualified expert who will provide reliable and relevant opinions, as required by Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). (See Def. Mot. 3). Second, evidence relating to Minor Victim-3 is admissible both as dir