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

ealing with an 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

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

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

- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were not specifically By PAUL G. CASSELL, ESQUIRE 14 IC disclosed would net be permitted CO be used at. 25 For Jeffrey Epstein: 17 trial. You nada it clear that catchall listings 16

ow all of S to whom have you distributed them? And those are 8 the lewyer0 involved. , questions that we still don't have answered. 9 And Hr. Cassell is going to address free the 10 what we get frog the other side is, 'Well, 10 perspective of the client. the concern that they 11 they could ha

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

- and I think it nay have been the 14 De her 22 dice -- I'm not sure about that exact 13 la date -- bat exhibits that were not specifically By PAUL G. CASSELL, ESQUIRE 14 1a disclosed would net be penn/Lted CO be used at. 25 For Jeffrey Epstein: 17 trial. You rude it clear that catchall listings 16

ow all of S to whom have you distributed them? And those are 8 the lewyer0 involved. , questions that we still don't have answered. 9 And Hr. Cassell is going to address free the 10 what we get frog the other side is, 'Well, 10 perspective of the client. the concern that they 11 they could ha

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

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

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

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-

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

By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe HATCH, JAMES 4 DODGE, P.C. 10 Nest Broadway, Suite 400 Salt Lake City, UT 84101 By PAUL G. CASSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBURY, GOLDBERGER 4 WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK

none that itie in Rickard County, to ay knowledge, and has done we attached -- were communications between an attorney and a client. I asked Hr. Cassell and I asked Mr. Scarola to INB KB a senior work here In the 15th Judicial Circuit somehow engaged in some type of ex parte onsminications with

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

Victims' Right Act is still potentially in jeopardy for prosecution, because they have purposely -- and Mr. Edwards and an attorney by the name of Cassel, I believe, have prosecuted that. It is still going on. And they control at least their side of that litigation. And it is because of that that Mr

we get an answer on the record as to whether that is going to happen so I know whether this is discovery that I need to proceed with. THE COURT: Binger has long held, essentially, that there's really no difference from the discovery standpoint between rebuttal witnesses or rebuttal evidence and d