EFTA00806712.pdf

IN THE CIRCUIT COURT OF THE H1- 1 EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S 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 DETERMINATION ON HOW THE DOCUMENTS SHALL BE TREATED Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") gives notice that, in light of the parties' differing views over the potentially privileged nature of the documents attached to Epstein's Appendix in Support of his Response in Opposition to Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") Second Supplement to Motion in Limine Addressing the Scope of Admissible Evidence, Epstein will not oppose Paul Cassell or Edwards filing a Motion seeking to seal the documents in accordance with the requirements of Administrative Order 2.303-0/09 until such time as the Court has made a determination on Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, and Request for Additional Limited Discovery, Evidentiary Hearing and Appointment of Special Master. Paul Cassell, who has appeared on behalf of E.W., L.M. and Jane Doe, has requested that the documents be sealed to protect his clients' interests, however, his clients' names were redacted from the Court filing. EFTA00806712  Edwards' counsel's assertion that Epstein's current counsel obtained the documents in some inappropriate or unethical way is completely without merit. Epstein has already notified Edwards' counsel and Cassell that if they will identify by Bates number the documents they assert are attorney-client communications, Epstein will segregate and seal those documents. Lastly, Epstein wants the Court to understand that his agreement to not object is not based on any doubt in his position that the documents on the disc were produced many years ago and that the disc contains relevant and highly material e-mails that Epstein believes are case ending. Because the disc was also produced to William Scherer in the Razorback litigation and because some of the documents they claim were not to be produced were attached as exhibits to Edwards' deposition in 2013, any work product protection has long ago been waived. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on March 6, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 11110111.1 [fax] By: /s/ Scott J. Link (FBN Kara Berard Rockenbaclial Angela M. Many (FBN Primary: Primary: Primary: Secondar Secondar Secondar Secondar Trial Counselfor Plaintiff/Counter-Defendant Jeffrey Epstein 2 EFTA00806713  SERVICE LIST Jack Scarola Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, P.A. Burlington & Rockenbach, P.A. 2139 Palm Beach Lakes Boulevard Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counselfor Defendant/Counter-Plaintiff Co-Counselfor Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Bradley J. Edwards Marc S. Nurik Edwards Pottinger LW Law Offices of Marc S. Nurik 425 N. Andrews Avenue, Suite 2 One E. Broward Boulevard, Suite 700 Ft. Lauderdale. FL 2 Ft. Lauderdale, FL 33301 Counselfor Defendant Scott Rothstein Co-Counselfor Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger VIA EMAIL Atterbury, Goldberger & Weiss, P.A. Paul Cassell 250 Australian Avenue S., Suite 1400 383 S. University Str. West Palm Beach, FL 33401 Salt Lake City, UT 84112-0730 • Co-Counselfor L.M., E.W. and Jane Doe Co-Counselfor Plaintiff/Counter-Defendant Je re E.stein VIA EMAIL Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 jayhowell.com Co-Counselfor L.M., E.W. and Jane Doe 3 EFTA00806714