Epstein Secrets

d Haddad an) John Scarola irsETPH \CKERMAN JR Maria Kelchian ~la) Matthew D Weissing II~M) Pi 4IMP

-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

nt 04/09/18 Epstein's Response in Opposition to Farmer Jaffe's Motion for Issuance of an Order to Show

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

g that i➢ generated as a 23 stamped documents to the special master and an 23 consequence of that prod➢➢. It contains those 24 identical set to Farmer, who will use the name to 24 privileged and attorney work product emmila. And 25 create its privilege log. 25 that assertion of privilege hes n

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

g that i➢ generated as a 23 stamped documents to the special master and an 23 consequence of that prod➢➢. It contains those 24 identical set to Farmer, who will use the name to 24 privileged and attorney work product emmila. And 25 create its privilege log. 25 that assertion of privilege hes n

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

ecial Master he would then only list on the new privilege log work product materials for existing cases and attorney-client privilege materials. Id. Farmer confirmed this agreement more than once: [February 9, 2011] "We also have 2 more boxes that contain work product materials what we will turn over

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

dge, I understand 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 a

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

he was being followed or watched. And as it turns out, you'll see at 335, that the Rothstein firm -- I'm sorry, this is in March of 2010, that the Farmer, Jaffe, Edwards firm hired investigators to go to his house and they were able to identify Richard Fandrey and Michael Fisten. Michael Fisten was

tion -- THE COURT: That's what I'm doing today until the noon hour. MR. LINK: Great. Thank you, Your Honor. MR. SCAROLA: And there is a threshold Binger issue, which my presentation addresses that I provided to opposing counsel but have not yet given to Your Honor. I can give it to Your Honor now,