Epstein Secrets

STRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S OPPOSITION TO MESSRS. CASSELL AND EDWARDS' RENEWED MOTIONS TO APPEAR PRO HAC VICE Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the following opposi

he supplements] over to the defense," the Plaintiff and pro hac vice applicants Cassell and Edwards filed with the Court: • at 5:33 p.m. Motion for Paul G. Cassell to Appear Pro Hac Vice (Doc. #112), which referenced "supplemental materials submitted at the hearing today"; EFTA00605448 • at 5:59 p.m., Letter

a portion of the case on appeal. See Edwards v. Epstein and Scott Rothstein (Mr. Edwards' former law partner), District Court of Appeal of Florida, Fourth District, No. 4D14-2282. This Court advised the pro hac vice applicants that "I think it would be inappropriate for you to be counsel if you have the potent

(3/8/18 Aft. Tr. 78:9-25) (emphasis added). Paul Cassell, the Intervenors' counsel, asked that a similar r

t representation, as Mr. Scarola has accepted those representations during the hearing as well. (3/8/18 Aft. Tr. 78:9-25) (emphasis added). Paul Cassell, the Intervenors' counsel, asked that a similar representation be made by Fowler White. In response, the Court referenced a "blanket confidentiality

dwards, 4'h DCA Case No. 4D18-0787. (Composite Exhibit C.) CONCLUSION Epstein's general references in pre-trial filings with this Court and in the Fourth District Court of Appeal to the 47 exhibits in question are fully compliant with the Court's rulings at the March 8, 2018 hearing. Epstein has not dissemina

ntroduce to Your Honor II 12 For Non-Parties L.M.. E.M. 4 Jane Doe 13 University of Utah Law Professor Paul 13 HATCH. JAMES 4 DODGE, P.C. 14 Cassell, former Federal Judge Paul Cassell, 15 who will present that matter to the court. 14 Y 16 MR. CASSELL: Good morning, Your Honor. 15 17 Since

For Non-Parties L.M.. E.M. 4 Jane Doe 13 University of Utah Law Professor Paul 13 HATCH. JAMES 4 DODGE, P.C. 14 Cassell, former Federal Judge Paul Cassell, 15 who will present that matter to the court. 14 Y 16 MR. CASSELL: Good morning, Your Honor. 15 17 Since this is an unopposed motion, it wi

t for record, the case I keep on my bunch is Palm Beach Polo holdings, Inc., et. al versus Broward Marino, Inc. I have the original email from the Fourth District Court of Appeal copy. So I don't have a cite for you, but it's from 2015. That's easily accessible if you'd like to road it. MR. LINK: Thank you.

in appellate proceedings; communications with P. Cassell re proposed sealing order and no authority to ad

. Rockenbach to have in the pipeline, pending outcome of 3/8/18 hearing; review appellate rules of procedure on certiorari and mandamus relief and Fourth District Court of Appeal's Administrative Order re requests for emergency relief 03/04/18 SJL Work on strategies re case not at issues, Petition for Cert

ed to Support J. Epstein's Claims Against B. Edwards; work on Emergency Motion for Writ of Mandamus; telephone conferences with P. Cassell; review Cassell's filings and follow up on issues raised by same; communications with P. Cassell and J. Scarola re production of disc; communications with D. Indy

e all r. 90.702, work-product pr inethical behavior, is; onse in Opposition to Pr eider from the Fourth Di P. Cassell's Pro Hac Vi. ) the Fourth District Cc Ida+ for panel purposes 03/17/18 TLC Cr c, ionology of Ix i, .; review court filings, tr; r re same 03/17/18 SJL C( ) I Edwards' Resp