Epstein Secrets

4:13-14. However, when given the option to waive any technical argument under Rule 1.440, they declined to do so: MR. LINK: Thank you. I know Mr. Scarola said they're excited to try the case, believe me, Judge, we are really excited to try the case. The evidence that we recently discovered — THE C

CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all all Counsel on the attached list, this an day of July, 2018. c JACK SCAROLA Florida Bar No.: 169440 KAREN E. TERRY Florida Bar No.: DAVID P. VITALE JR. Florida Bar No.: Attome E-Mails: •••••••• ;and Primary E-Mail:

040800XXXXMBAG Response in Opposition to Epstein's Motion to Amend Exhibit List. nothing more than another hyper-technical argument. Les Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006) ("The elements of waiver are: (1) the existence at the time of the waiver of a right, priv

o E-Mail s ; and rimary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulev

ge or benefit which may be waived; (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the 2008 Doe v. United States proceeding impeded

t e E-Mail ; and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulev

d for October 3, 2017 Page 4 of 8 (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the 2008 Doe v. United States proceeding impeded

E-Mail: [email protected] Seamy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes B

ge or benefit which may be waived; (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency. Inc. 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the Doe v. United States proceeding justifies a s