Epstein Secrets

or Plaintiff/Counter-Defendant Jay Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730

ry, Goldberger & Weiss, . 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jay Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 [email protected] Limited Intervenor Co-Counsel fora., E. It". and Jane Doe Jay Howell Jay

expert which is otherwise qualified to testify to what he's going to testify. (3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which should pertain in only the most compelling

Goldberger & Weiss, M. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University St. Salt Lake City, UT 84112-0730 Limited Intervenor a -Counsel for E.W. and Jane Doe Jay Howell Jay Howell & Associates 64

Containing Privileged Materials Page 4 — Provided illustra ive samples of e-mails: • 4408-4412 is an 10/17/09 e-mail exchange between Edwards and Cassell. • 4399-4400 is an 10/17/09 e-mail exchange between Edwards and Cassell. • Multiple e-mails dated 10/23/09 about Edwards' direct participation wi

l by way of memorandum, and that will be done under seal and will continue to be under seal, and will be filed under seal in case of Ringer v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2 EFTA00808705 a need for appellate review. So that is going to be the direction of the Court, that the motion be

ivilege" (only 19 were communications with a client as determined by the description in the privilege log). 17 EFTA00794293 Despite Edwards' and Paul Cassell's (counsel for the Intervenors) protestations to the contrary, this Court can plainly see that not a single one of the 30 e-mails are attorney-client

hat not a single one of the 30 e-mails are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cass

Link & Rockenbach, PA discovered documents that were voluntarily produced years ago by Edwards to his potential adversaries at the 6Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 3 EFTA00794279 time — the Razorback plaintiffs. These e-mails directly contradict Edwards' sworn testimony and pos

ue S., Suite 1400 West Palm Beach, FL 33401 igoldbergerRagwpa.com [email protected] Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University St. Salt Lake City, UT 84112-0730 cassellpalaw.utah.edu Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell

laintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University St. Salt Lake City, UT 84112-

that any substantive discussion of those emails will be done under seal by way of memorandum, and that will be done under seal and 'Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2Excerpts of the November 2, 2018, Hearing Transcript are attached as Exhibit A. 2 EFTA00794299 will continue to b