Epstein Secrets

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

did not improperly obtain thee, nor were they inadvertently disclosed co us. 4 earlier attempted to exclude the surprise testimony • THE COURT: Tina Campbell is your paralegal? 5 by an unsuccessful notion in limlne. Furthermore, a MS. RCCICENBACH: 4010 obtained the three boxes, 4 prejudice in the con

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

did not improperly obtain thee, nor were they inadvertently disclosed co us. 4 earlier attempted to exclude the surprise testimony • THE COURT: Tina Campbell is your paralegal? 5 by an unsuccessful notion in limlne. Furthermore, a MS. RCCICENBACH: 4010 obtained the three boxes, 4 prejudice in the con

, which occurred on October 13, 2018. Due to the impermissible questions, Epstein additionally moves this Court to require Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), Bradley J. Edwards ("Edwards") and Intervenor L.M. ("L.M.") (collectively, the "Movants") to pay Epstein's

impermissible questions, Epstein additionally moves this Court to require Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), Bradley J. Edwards ("Edwards") and Intervenor L.M. ("L.M.") (collectively, the "Movants") to pay Epstein's attorneys' fees for the excessive time spent at the depositi

ined images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards, or his client. (D.E. 1194.) During the April 13, 2018,' hearing on the Motions, Edwards' counsel asked the Court to be allowed to take the deposi

25:8-26:15). Mr. Link was also asked a long line of questions about his firm's review of the disc after its discovery: Q. How did she [Paralegal Tina Campbell] review the disc contents? Rockenbach (counsel for Mr. Link): I am going to object on the basis of, not only work product protection, but that thi

SCAROLA: Thank you, air. Your Honor, have uo decided what notions we're going to hoar? THE COURT: Yes. My understanding as I la;' was going to be Edwards' Second Supplement to Motion in Lamine Addressing Scope of Admissible Evidence, and of course in that sane vein roster'. Notice of Service of Unre

nderstand that. I otherwise, the Court retains jurisdiction to award 9 THE COURT: Titoorder eays that Fowler Mit. sanctions in favor of Farmer, Brad Edwards or his 10 will not retain any copies of 0he documents .1 client," end quote. 1i contained on the disk provided to it nor shall any • MR. LIN

inadvertently disclo.. And it aaya, quote, 'The opposing party also a to us. i earlier attempted to exclude the surprise testimony 4 THE CURT: Tina Campbell is your paralegal' • by an unsuccessful notion in limlne. Furthernare, 5 /12. ROCWITEACH: Who obtained the three boxes. prejudice in the context

ACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite West Palm Beach, FL 33401 301 By SCOTT J. LINK, ESQUIRE 5 By JENNIFER LETTMAN, ESQUIRE 6 For Bradley Edwards: 7 SEARCY, DENNEY, SCAROLA, BARNHART & 8 SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard 9 West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE

0 21 22 23 24 25 INDEX Videotaped Deposition of JAMES N. HURLEY, ESQUIRE Page No. Direct Examination by Mr. Scarola Cross-Examination by Mr. Edwards Cross-Examination by Mr. Link Redirect Examination by Mr. Scarola Recross-Examination by Mr. Link Further Redirect Examination by Mr. Scarola Re

e delivered to the Link firm, they were done in two stages. The first stage, the Link firm came to our office -- I believe it was Scott and mostly Tina Campbell -- to review the documents. They flagged certain documents that they wanted to have received. We provided copies of the hard documents that they