Epstein Secrets

ldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach. FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 [email protected] Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay

laintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730

F HIS SUPPLEMENT TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS, ETC. As supplemental authority in support of his Motion for Court to Declare Relevance and Non- Privileged Nature of Documents and with Specific Request for In Camera Review to Determine Relevance, Inapplicability

NG, EDWARDS, FISTOS & LEHRMAN, M. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone Facsimile Florida B E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, UT 84112 Telephone Facsimile: E-Mail: Atto

hone Facsimile Florida B E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the

arguments that the victims had not seen before in the three-and-a-half years that this case has been litigated. The victims then filed under seal a Motion for Court to Deny the Motion to Dismiss Based on Existing Pleadings or, at a Minimum, Allow Leave to File a Sur-Reply. That motion explained that the Governm

ds Marc S. Nurik Law Offices of Marc S. Nurik Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbur , Goldber . er & Weiss, P.A. - Paul Cassell Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein. Jay Howell Jay Howell & A

r Atterbur , Goldber . er & Weiss, P.A. - Paul Cassell Limited Intervenor Co-Counsel for L.M., E.W. an

s Permission to Alter Trial Evidence by Replacing Names with Initials of Edwards' Three Clients on Trial Exhibits [D.E. 1240] 15 3/5/18 Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special Ma

om the disc and any copies of the discs that they had in their possession. • On March 6, 2018, Epstein filed his Notice of No Objection to Attorney Paul Cassell, on Behalf of L.M., E.W. and Jane Doe, or Defendant/Counter-Plaintiff Bradley J. Edwards Moving to Seal Court Records Until the Court Makes a Deter

berger 4 - to op .. - . . eiss, P.A. Paul Cassell Suite 1400 0730 ' II Limited Intervenor Co-Co

ndix in Support of Response in Opposition to Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence, and D.E. 1252, Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for 2 EFTA00793756 Additional Limited Discovery, Evidentiary Hearing and

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

from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440; work on Response to B. Edwards' Motion for Separate Trials; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special M