Epstein Secrets

biting any reference to or use of the exhibits at the trial. (3/18/18 Aft. Tr. 75:24-76:6.) This, 3Edwards claimed it is 49 exhibits, but two of the Bates numbers he referenced were pages contained within another exhibit, making the total 47 exhibits which are in dispute. 3 EFTA00808660 of course,

ng, Edwards, himself, would be in violation of the Court's ruling by his reference to the e-mails in filings in this Court, the Appellate Court and the Bankruptcy Court. In fact, Epstein has taken numerous affirmative steps to ensure compliance with the Court's directives at the March 8, 2018 hearing. The disc is se

n pertinent part as follows: [T]he law firm of Fowler White Burnett, ■., will print a hard copy of all of the documents contained on the discs with Bates numbers added, and will provide a set of copied, stamped documents to the Special Master and an identical set to Fanner, who will use same to creat

er White's possession and retention of the CD at issue is currently the subject of a Motion for Issuance of an Order to Show Cause that was filed in the Bankruptcy Court on March 19, 2018. The Bankruptcy Court has scheduled a hearing on that motion for April 13, 2018. 4 EFTA00811314 Edwards adv. Epstein Case No.

face of Edwards' privilege log, Epstein has no way to determine whether the work product privileges claimed are fact or opinion work product. (See Bates . (Ex. F). It is essential that sufficient information be provided by Edwards to distinguish between fact and opinion work product because Epstein

f would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Edwards, in response to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA04