Epstein Secrets

[email protected] Counsel for Plaintiff in Related Case No. 08- 80893, - • Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 2

e theory of the requestor's case, or to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA 2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact work product where the requesting party can show need and the inability to obtain the substantia

Avenue S., Suite 1400 West Palm Beach. FL 33401 MOW Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm B

ties Fowler White and Farmer Jaffe consent to the jurisdiction of this Court solely for purposes of participating in the mediation. 2. Pursuant to Florida Rule of Civil Procedure 1.720, Edwards, Epstein, the Intervenors and representatives from Fowler White and Farmer Jaffe who have the full authority to settle wit

in 2 EFTA00806692 Jack A. Goldberger Paul Cassell Atterbury, Goldberger & Weiss, P.A. 383 S. University 250 Australian Avenue S., Suite 1400 Salt Lake City, UT 84112-0730 West Palm Beach. FL 33401 cassellpalaw.utah.edu Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintif

IN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / NOTICE OF VOLUNTARY DISMISSAL WITH PREJUDICE Pursuant to Florida Rule of Civil Procedure 1.420, Counter-Plaintiff Bradley J. Edwards and Intervenors L.M., E.W. and Jane Doe, voluntarily dismiss with prejudice Edwards' Counterc

n 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 644 Cesery Blvd., Suite 250 Jacksonville

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc

252 Fax: (202)-719-7049 Attorneys for Alan M. Dershowitz Joni J. Jones, Esquire [email protected] Assistant Utah Attorney General 160 E 300 S Salt Lake City, UT 84114 Phone: (801)-366-0100 Fax: (801)-366-0101 Attorneys for Paul Cassell EFTA00602650

T FOR PRODUCTION TO DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS and PAUL G. CASSELL, by and through their undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby request Production from Defendant, ALAN M. DERSHOWITZ, of the documents and things described below for the purpose of inspe

f/Counter- Defendant Jeffrey Epstein VIA U.S. MAIL Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach,

ify them on his Exhibit List. Edwards has provided not a single reason why this Court should expedite its careful review and enforce the mandate of Florida Rule of Civil Procedure 1.440 (Petition for Writ of Mandamus) and determine if the severance of the interrelated and dependent actions should continue to one jur

L 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 Jay Howell & Associates 644 Cesery Bl

ils), Edwards clearly waived any work-product protection he may have had by — among other compelling reasons -- his complete failure to comply with Florida Rule of Civil Procedure 1.280(b)(6). With Epstein's citation in his motion to the Fourth District Court of Appeal's controlling case of General Motors Corp v. Mc