EFTA00702990.pdf

From: Scott Link -4 To: "[email protected]" [email protected]> Subject: Fwd: Epstein v. Edwards - Meeting Follow Up Date: Wed, 25 Oct 2017 10:46:43 +0000 Jeffrey I thought I would send this so you can see where we are headed. I'm not sure how much of the minutia/details you want forwarded to you. Let me know what level of information you would like to see. Scott Sent from my iPhone Begin forwarded message: Front: Tina Campbell Date: October 25, 2017 at 6:44:58 AM EDT To: "Darren hid ke "Brinson, Crystal ( Scott Link ,'Kara Berard Rockenbach' 9 • Subject: Epstein v. Edwards - Meeting Follow Up Good morning, Following up to yesterday's meeting, below are some of the more immediate to do items and upcoming deadlines. Please review the list and let us know if you have anything to add. Immediate To Do • Jack — set up meetings with Critton and Ackerman (Jack/Darren/Scott/David/Kara) and also ensure we get their files • Tonya/Jack — to send us their files — Gunster will arrange copy service (I have already coordinated with Chet for his files; Crystal/Gunster to coordinate today about getting Tonya's and Jack's files) • Tina/Darren — work on chronology (I am working on first draft and will send to Darren) • Tom/Tim — work on verdict forms, statement of facts and case summary for focus group (by 10/27) Other To Do Items • Set deposition of Edwards' Expert • Draft Mediation Statement (11/10 to mediator — circulate draft in advance) • Review Exhibit and Witness Lists - Gunster • List objections to Edwards' Exhibits (due 11/6) - Gunster • Pretrial Stipulation (due 11/15) — Jack/Kara • Bench Memo — Tom/Tim • Review Edwards' deposition designations to determine if we should object/cross-designate (due 11/27) - Gunster • Review pending Motions - Gunster o 9/25/17, Edwards' MIL to Strike the 6/30/17 Affidavit of Epstein and to Exclude Evidence as to Which Discovery Was Withheld EFTA00702990  o 9/25/17, Epstein's Omnibus MIL o 10/4/17, Edwards' Motion for Temporary Stay o 10/5/17, Epstein's Motion for Sanctions Pursuant to Violation of Confidential Settlement Agreement Against Edwards and his Counsel o 9/21/17, Edwards' four Motions to Compel o 9/25/17, Epstein's Motion to Compel Upcoming Deadlines 10/23/17 DEADLINE: To serve discovery — by portal/e-mail — so discovery is completed by 11/27/17 10/27/17 DEADLINE: To serve discovery — by hand or fax (to avoid 5 "mail days") so discovery is completed by 11/27/17 10/27/17 INTERNAL DEADLINE: Drafts of the Verdict Forms and Case Summary for Focus Group — Tom/Tim 11/2/17 12:30 — 5 p.m. Focus Group — Embassy Suites 11/6/17 DEADLINE: Parties to confer to discuss settlement, simplify the issues, stipulate in writing to facts and issues, prepare a Pre-Trial Stipulation and list objections to exhibits [30 days prior to trial] 11/10/17 DEPO: Bradley Edwards @ Searcy Denny 11/10/17 DUE: Certificates of Authority for Mediation; Mediation Statement 11/12/17 DEADLINE: Bradley Edwards to appear for deposition 11/15/17 DUE: Pre-Trial Stipulation, Deposition Designations, Proposed Jury Instructions and Verdict Form; DEADLINE: To have Daubert Motions heard [20 days prior to trial] 11/17/17 DUE: Edwards' Answers to our Expert Interrogatories and RFP 11/20/17 DEADLINE: Plaintiff to accept OUR Proposal for Settlement 11/20/17 @ 10:00 a.m. MEDIATION — Brian Spector --- NEED TO GET LOCATION CHANGED — set at Searcy Denny — David — can we use Gunster's offices? 11/27/17 DEADLINE: To complete discovery; DUE: Counter deposition designations and objections to original designations [10 days prior to the first day of trial) [note, deadline falls on Saturday of Thanksgiving weekend — 11/25/17 — calendared next business day] 12/4/17 DEADLINE: To mediate 12/5/17 Commencement of 10-day trial EFTA00702991 Tina L. Campbell, CP/FRP Certified Paralegal/Florida Registered Paralegal 777 South Flagler Drive, Suite 800 East I West Palm Beach, FL 33401 I F: I Email: This e-mail may contain privileged or confidential information. If it is not meant for you, please delete it and notify us immediately. Please confirm receipt of time sensitive communications because email deliveries may be delayed or unsuccessful. We do not provide tax advice. Our communications may not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service. EFTA00702992