DS9 Document EFTA01103138

1 3 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR 1 The above-styled cause came on for PAIN BEACH COUNTY, FLORIDA CASE NO. 50-2019-CA-041910-XXXX-MB-AG 2 hearing before the Honorable David Crow, 3 Circuit County Court Judge. at the Palm Beach JEFFREY EPSTEIN, Plaintiff/Countor-Detondant, 4 5 6 County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida, on June 5, 2013, commencing at 8:55 o'clock, p.m., as follows: SCOTT ROTHSTEIN, individually, and 7 THE COURT: Good morning. This is BRADLEY J. EUtaRDS, individually, Defandants/Counter-Plaintiffs. 8 Epstein versus Rothstein. Actually, this is a / 9 status conference, as well as 1 think the 10 plaintiff filed a motion for clarification. I TRANSCRIPT OF HEARING Volume 1 of 1 11 read the motion. Do you want to add anything Page: 1 - 19 12 else to the written motion? DATE: Monday. June 5, 2013 TIME: 9:55 o'clock, a.e. 13 MS. COLEMAN: No, Judge. I brought all PLACE: Palm Roach County Courthouse 14 the case law with me, but I attached your 205 North Dixie Highway West Palm Beach, Florida 33401 15 previous March 11th order, as well as the BEFORE: Honorable David Crew, Circuit Court Judge 16 subsequent May 17th order, which was the This cause came on to be hoard at the time and place aforesaid. The following proceedings 17 portion with which we took issue for the wore reported by: 18 clarification. Roger Watford, RPR/FPR 19 THE COURT: lam not sure what the U.S. Legal Support, Inc. 444 West Railroad Avenue 20 clarification is. Let me just say I thought Saito 300 21 the order was clear. Here's what it said. Host Palm Beach, Florida 33401 (5811 835-0220 22 It said very simply that I initially 23 ordered you to produce a privilege log for 2 4 anything that was an non-constitutional 2 5 privilege and you do not have to provide a 2 4 1 APPEARANCES: 1 privilege log which in and of itself may be 2 FOR THE PLAINTIFF/COUNTER-DEFENDANT: 2 incriminating. I understood that that was 3 LAW OFFICES OF TONJA HADDAD COLEMAN. PA. 3 your position. 4 315 Southeast 7th Street 4 !expected there would be a list of Suite 301 5 documents, which only was an objection based 5 Fort Lauderdale. Florida 33301 6 on some non-constitutional privilege. What 1 6 954-467-1223 BY: TONJA HADDAD COLEMAN. ESQ. 7 got, what was provided, was essentially, 7 8 although you did produce some documents, 8 FOR THE DEFENDANT/COUNIER-PLAINTIFF: 9 substantially all the documents were objected 9 SEARCY. DENNEY. SCAROLA. BARNHART 10 to not only on the Fifth Amendment privilege 10 & SHIPLEY. PA. 2139 Palm Beach Lakes Boulevard 11 but also on the basis of work product, West Palm Beach, Florida 33409 12 attorney/client privilege and various other 11 561-686-6300 13 non-constitutional privileges. BY: JACK SCAROLA. ESQ. 14 We had a hearing on that, and I think I 12 13 15 asked counsel what do I do under these 14 16 circumstances, and I don't recall the direct 15 17 response, but it was not a lot of information 16 18 1 got from you. 17 18 19 So what Idid is I went back and 1 had 19 20 some of our cracker-jack legal staff here do 20 21 some independent research for me, and after 21 22 reviewing that information I understand the 22 23 23 law to be, as I set forth in my order, that a 24 24 blanket objection on Fifth Amendment 25 25 constitutional grounds is generally 1 (Pages 1 to 4) WWW.USLEGALSUPPORT.COM 561-835-0220 3189172c-5e99-4994-al a9-015bd84662c8 EFTA01103138 5 7 1 unacceptable, and the Courts have outlined a 1 not there is a Fifth Amendment privilege, 2 methodology by which the Court can test the 2 like, for example, as I understand, the 3 legitimacy of a Fifth Amendment claim when 3 production of documents, the actual production 4 it's basically a broad brush. 4 itself must be testimonial, not the document 5 And that methodology, as outlined in the 5 nactessarily, and there are various different 6 cases I cited, is that you ask for and obtain 6 things I have to look at, and I recognize that 7 an in camera privilege log, one that is not 7 your client deserves, you know, the utmost 8 provided to the other side, an in camera 8 protection of his constitutional fights. 9 privilege log directed to the Court alone that 9 But the pragmatic reason I thought out 10 outlines; one, the document, and provides me a 10 loud in my order was that, what happens then. 11 copy of the document; two, the privilege that 11 I would be able to rule on your 12 you are asserting, whether it be 12 non-constitutional privileges, because at 13 constitutional or non-constitutional; and the 13 trial, very simply, what can happen is, you 14 third, the basis that you feel, at least on 14 can't ask somebody at trial an attorney/client 15 constitutional grounds, that the production. 15 privilege question, you can't ask them a work 16 for example, is, in fact, testimonial and that 16 product privilege question, so if the only 17 you have a reasonable basis to believe that 17 privilege remaining is, in fact, subject to 18 producing the document, if it's an individual 18 self-incrimination under the Fifth Amendment, 19 or a corporation, would, in fact, incriminate 19 that can be asked of the witness on the stand. 20 the client. 20 and he must assert his right at the time of 21 As I understand the case law, the Court 21 trial, and the jury can take whatever they 22 is then to look at that in camera production, 22 want to from that. 23 nobody gets a copy of it, I take a look at it, 23 That's the reason I set forth this 24 I make a decision whether or not there is, in 24 procedure. I'm sorry it wasn't clear. That's 25 fact, a good faith basis for a constitutional 25 the procedure I set up. But do you want me to 6 8 1 objection on Fifth Amendment grounds. 1 reconsider that theory or you just didn't 2 Also I look at the documents to determine 2 understand what I was doing? I'm not sure I 3 whether or not the other privileges apply, the 3 understand what you're asking. 4 attorney/client privilege, work product 4 MS. COLEMAN: I understood your order. 5 privilege, accountant privilege, and, if I 5 but it was in direct contravention with your 6 can, I make rulings based upon that internal 6 first order, and it -- 7 privilege log or in camera privilege log. 7 THE COURT: Well, the initial order 8 In fact, the case law goes forward from 8 contemplated that there would be a subset of 9 there and actually says, if I can't determine 9 documents which were privileged based upon 10 it from that, I can actually have an in camera 10 non-constitutional grounds that I could look 11 hearing where I can have you and your client 11 at and make determinations on, but the reality 12 appear and produce additional information to 12 is that they apply to all of them, so there's 13 me to allow me to make that decision as to 13 no way I can look at the documents and make 14 whether or not the documents in good faith are 14 determinations on work product, attorney/ 15 constitutional. 15 client, accountant privilege, lam not sure of 16 No one is trying to abrogate your 16 all the other privileges, without looking at 17 client's Fifth Amendment privilege, but there 17 the document, and that's what I asked and did 18 has to be a method to test whether there's a 18 research on. to determine how I look at a 19 good-faith basis for it and to rule on the 19 document that is claimed to be Fifth Amendment 20 other privileges, and if I need a further 20 privileges. 21 hearing, I can have a further hearing. Mr. 21 And the Federal Courts have set up a way 22 Scarola is not a part of that. Then I make a 22 to do that because, otherwise, people would 23 ruling. 23 just have a blanket assertion. In fact, there 24 And the pragmatic and practical reason 2 4 are two Supreme Court cases I think I cited, 25 for that is not only to determine whether or 2 5 one where they said. yeah, the other one said, 2 (Pages 5 to 8) WWW.USLEGALSUPPORT.COM 561-835-0220 3189172c-50,99-4994-al a9-015bd84662c8 EFTA01103139 9 1 no, and then there's a lower court setting 1 criminal, respectfully, this Court cannot 2 forth a procedure to do it. 2 confer immunity upon my client from 3 MS. COLEMAN: The problem with which we 3 prosecution of that. 4 are faced with, Judge, is this: 4 In fact, I believe under the Judicial 5 We did not assert a blanket Fifth 5 Canons, you would be obligated to turn it 6 Amendment privilege. It was very specific as 6 over. And we proffered this, and I did cite 7 to certain requests to which we argued. And 7 case law in our motion for clarification in 8 the interrogatories was the other portion of 8 which we asserted that a proffer from the 9 which we were requesting clarification of, but 9 attorney is specific enough, and we have laid 10 I will address that momentarily. 10 it out many times. 11 If the documents are provided to you, 11 THE COURT: Which case is that? 12 even for an in camera review, the Fifth 12 MS. COLEMAN: The proffer from the 13 Amendment privilege is waived. Respectfully, 13 attorney would be sufficient, ironically, it's 14 Judge, hypothetically speaking. if you saw 14 in regards to Rothstein versus Albert, which 15 something -- 15 is cited on page 6 of our motion. And, in 16 THE COURT: You mean I got it totally 16 addition, Judge, there are cases where, if you 17 wrong? 17 look at all the other cases to which we refer, 18 MS. COLEMAN: Judge, I am not trying to 18 it's a realistic fear of future prosecution. 19 say you got it totally wrong, but the case law 19 We have delineated in here, this is a 20 research, my case law research and the 20 unique situation, Mr. Edwards is actively 21 research that the criminal defense attorneys 21 seeking to overturn a non-prosecution 22 with whom I'm working, states that -- 22 agreement between Mr. Epstein and the United 23 THE COURT: What case are you relying 23 States government. Part of the allegations by 24 upon? Actually, I ran this by somebody who 24 the United States government, and again of 25 teaches this that's a colleague of mine, 25 course I am not saying they are true, part of 10 12 1 teaches federal prosecutors the issue. Which 1 the allegations to which the government was 2 case are you relying upon? 2 referring included financial crimes. 3 MS. COLEMAN: I am looking at Pisciotti 3 As such, if any of this financial 4 versus Stephens; 940 So.2d, 1217; Maged versus 4 information is provided to this Court and/or 5 Winter, 664 So.2d -- 5 if Mr. Edwards is successful in his quest to 6 THE COURT: Where in your motion is it? 6 do this, the docket is 427 entries long, it's 7 MS. COLEMAN: I'm on page 3 of my motion 7 an active case, Mr. Epstein runs the risk of 8 for clarification. 8 being prosecuted for these things should there 9 THE COURT: Okay. And it's Maged versus 9 be anything incriminating therein. 10 Winter? 10 The biggest issue with which we arc 11 MS. COLEMAN: If you turn to page 3, 11 faced, Judge, is if the mere act of producing 12 Judge, that entire page, it discusses -- 12 these documents or identifying these document% 13 THE COURT: It says the production in 13 would waive his Fifth Amendment privilege. 14 camera to the Court to determine the validity 14 then he has lost that Fifth Amendment 15 of the Fifth Amendment privilege waives the 15 privilege. 16 privilege? 16 I do appreciate the concern with respect 17 MS. COLEMAN: It does, Judge. If you 17 to the other privileges, and I don't have an 18 would allow me to finish, I will explain to 18 answer, if I had been able to find one I would 19 you the issue. 19 have given it to you, but the risk we're faced 20 THE COURT: Okay, I'm sorry. 20 with today is that if he must lose all those 21 MS. COLEMAN: Hypothetically speaking, 21 other privileges, accountant/client, 22 let's say the documents are given to you and 22 attorney/client, work product, and only be 23 you see something that in and of itself would 23 permitted to assert the Fifth, then that's 24 constitute a reason to assert the Fifth 24 what he is going to have to do, because I 25 Amendment, it could possibly be deemed 25 don't see any way in which the client can 3 (Pages 9 to 12) WWW.USLEGALSUPPORT.COM 561-835-0220 3189172c-50,99-4994-al a9-015bd84662c8 EFTA01103140 13 1 produce the documents. 1 situation under which my client can't turn 2 Again, I don't read any of these cases to 2 over any of these documents. 3 state that an in camera review of a privilege 3 So by actively seeking to overturn this 4 log would not waive the Fifth Amendment 4 non-prosecution agreement he places my client 5 privilege, I don't see that in any of these 5 in a legitimate fear that he could be 6 cases, which is why we were asking for the 6 prosecuted for anything that could arise out 7 clarification. 7 of this transactional event, including any 8 THE COURT: Okay. I'm going to have to 8 alleged financial crimes, because that is what 9 look at it again. This is complex stuff. 9 the government was initially alleging. 10 MS. COLEMAN: It is very complex, I don't 10 THE COURT: So your position, very 11 disagree. 11 simply, is in a civil case where there are 12 THE COURT: Okay, Mr. Scarola. 12 multiple privileges asserted to almost all the 13 MR. SCAROLA: I thought that I just heard 13 documents there is no methodology or method by 14 counsel offer to agree that the only 14 which the Court can determine the validity of 15 applicable privilege for purposes of this 15 those assertions and, therefore, Mr. Scarola 16 proceeding would be the Fifth Amendment 16 can't ask your client any questions? 17 privilege, and if that is what counsel is 17 MS. COLEMAN: Judge, again, I have not 18 prepared to agree to, that is an acceptable 18 seen a case -- I don't have an answer for 19 stipulation. 19 you. We can try to give you an answer on 20 That's what we have been asserting from 20 Monday. We have a one hour special set 21 the beginning of this controversy, that it is 21 hearing. 22 neercsary for the Court to implement a 22 THE COURT: I asked for that before I 2 3 procedure, which the Court has very clearly 23 thought. I didn't get a lot of help. I tried 24 outlined in Your Honor's order, which would 24 to do it on my own. 2 5 allow you to make a determination with regard 25 MS. COLEMAN: Because there's not a 14 16 1 to the validity of other privileges, even 1 simple answer out there. Judge, and I can't 2 assuming that the Fifth Amendment privileges 2 just blanketly waive my client's rights to all 3 were to apply. 3 his privileges without conferring with him, 4 If opposing counsel is agreeing that they 4 but the situation with which we are faced is 5 will waive privileges other than the Fifth 5 my client is now being put in a position where 6 Amendment privilege, in order to avoid the 6 he has to potentially waive any other 7 procedure that Your Honor has outlined, that 7 privilege he may be able to assert or waive 8 is acceptable, we accept that stipulation. 8 his constitutional privilege. 9 THE COURT: I don't think you are going 9 THE COURT: Okay, here's what I am going 10 to get it, but... 10 to do. I am going to stay production of the 11 MS. COLEMAN: Honestly, I don't know that 11 documents until I have a chance to look at 12 my client can be forced into that position. 12 this. Unfortunately, I'm in the middle of a 13 The bigger issue is, respectfully, again this 13 rather lengthy trial right now, and I will get 14 Court can't confirm immunity upon Mr. Epstein, 14 to it as soon as I can, but it won't be 15 and if there's anything in those documents to 15 tomorrow, it will be some time next week at 16 which a crime or a link to a crime could be 16 the earliest. But I will get you something 17 possibly furnished, the Court would have an 17 out as to what we're going to do here. 18 ethical obligation to turn it over. 18 MS. COLEMAN: Judge, the last part of the 19 If we could get the United States 19 clarification is, your order does speak to the 20 government, who is a party to this lawsuit 20 interrogatories, but you never actually said 21 with Mr. Edwards, to come in here and confirm 21 whether or not you expected further responses 22 immunity upon Mr. Epstein, I am sure there 22 to the interrogatories, and I cited some case 2 3 would be no issue with making a privilege log 23 law in our motion for clarification in which 2 4 and providing all these documents. But Mr. 24 the law is clear that interrogatories, because 2 5 Edwards, respectfully, has created this z 5 they must be verified and sworn to, arc 4 (Pages 13 to 16) WWW.USLEGALSUPPORT.COM 561-835-0220 3189172c-5e99-4994-al a9-015bd84662c8 EFTA01103141 17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 testimonial in nature. So that might be a little easier to answer, but please note that that was something with which we were also seeking clarification. THE COURT: Okay. Well, there are two categories of documents here, as I understand it. One is documents in the possession or alleged to be in the possession of your client, the other is documents which are in the possession of or are corporate documents or something like that. MS. COLEMAN: No, Judge, that was another portion of it. There are no corporate documents. All of the requests are to Mr. Epstein. THE COURT: I don't mean corporate documents, but documents that are not personal to him necessarily. MS. COLEMAN: I think the easiest way to go through this might be to look at each request individually, rather than trying to make these blanket or combination assertions, because -- THE COURT: The problem is you make blanket objections. 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 CERTIFICATE OF REPORTER I, Rogcr Watford, Florida Professional Reporter, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript is a trot and complete record of my stenographic notes. I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. Dated this 21st day of June, 2013 Rogcr Watford, FPR/RPR 18 1 MS. COLEMAN: We didn't, Judge. We 2 objected to each one individually. 3 THE COURT: In the same objection, like 4 you just mimeographed it. Well, y'alt are too 5 young to remember mimeographs. 6 MR. SCAROLA: Not all of us. 7 MS. COLEMAN: No, Judge, not to all of 8 them. Some of them, for example, may have a 9 work product type privilege or a third party 10 privacy right privilege. I'll just give you 11 an example: Any account on which Mr. Epstein 12 would have signatory authority. 13 THE COURT: Okay, I have to move on. I 14 will take a closer look at it. I have already 15 taken a close look at it. I will take a 16 magnifying glass to it, I guess, and get you 17 something out. 18 MS. COLEMAN: Thank you, Judge. 19 MR. SCAROLA: Thank you, Your Honor. 20 21 22 23 24 25 5 (Pages 17 to 19) WWW.USLEGALSUPPORT.COM 561-835-0220 3189172c-50,99-4994-al a9-015bd84662c8 EFTA01103142 Page 1 A able7:11 12:18 16:7 above-styled3:1 abrogate6:16 accept14:8 acceptable 13:18 14:8 account18:11 accountant6:5 8:15 accountant/client 12:21 act12:11 action19:14,15 active12:7 actively11:20 15:3 actual7:3 add 3:11 addition11:16 additional 6:12 address9:10 aforesaid1:20 agreei3:14,18 agreeing14:4 agreament11:22 15:4 Albert11:14 allegations 11:23 12:1 alleged15:8 17:8 alleging15:9 allow6:13 10:18 13:25 Amendment 4:10,24 5:3 6:1,17 7:1 7:18 8:19 9:6,13 10:15,25 12:13 12:14 13:4,16 14:2,6 and/or12:4 answer12:18 15:18 15:19 16:1 17:2 appear6:12 APPEARANCES2:1 applicable 13:15 apply6:3 8:12 : 1:3 appreciate 12:16 argued:n .7 asked4:15 7:19 8:17 15:22 asking8:3 13:6 assert7:20 9:5 10:24 12:23 16:7 asserted11:8 15:12 asserting5:12 13:20 assertion8:23 assertions 15:15 17:22 assuming14:2 attached3:14 attorney8:14 11:9 11:13 19:11 attorneys 9:21 19:13 attorney/client 4:12 6:4 7:14 12:22 authority18:12 authorized19:5 Avenue1:23 avoid14:6 a.m1:16 back4:19 BARNHART2:9 based4:5 6:6 8:9 basically5:4 basis4:11 5:14,17 5:25 6:19 Beach 1:2,16,17,24 2:10,10 3:3,5 beginning13:21 believe 5:17 11:4 bigger14:13 biggest12:10 blanket 4:24 8:23 9:5 17:22,25 blanketly16:2 Boulevard2:10 BRADLEY1:8 broad5:4 brought 3:13 brush5:4 C camera5:7,8,22 6:7,10 9:12 10:14 13:3 Canons11:5 casel:3 3:14 5:21 6:8 9:19,20,23 10:2 11:7,11 12:7 15:11,18 16:22 cases5:6 8:24 11:16,17 13:2,6 categories17:6 cause_ :. 3:1 certain CERTIFICATE 19:1 certify19:5,10 chance16:11 Circuit 1:1,1,18 3:3 circumstances 4:16 cite11:6 cited5:6 8:24 11:15 16:22 civi115:11 claim5:3 claimed8:19 clarification3:_C 3:18,20 9:9 10:8 11:7 13:7 16:19 16:23 17:4 clear3:21 7:24 16:24 clearly13:23 client5:20 6:11 7:7 8:15 11:2 12:25 14:12 15:1 15:4,16 16:5 17:9 client's6:17 16:2 close18:15 closer18:14 COLEKAN2:3,6 3:1' 8:4 9:3,18 10:3 10:7,11,17,21 11:12 13:10 14:11 15:17,25 16:18 17:12,19 18:1,7,18 colleague9:25 combination 17:22 come14:21 commencing3:6 complets19:8 complex13:9,10 concern12:16 confer11:2 conference 3:9 conferring16:3 confirm 14:14,21 connected19:14 constitute 10:24 constitutional 4:25 5:13,15,25 6:15 7:8 16:8 contemplated 8:8 contravention 8:5 controversy 13:21 copy5:11,23 corporate 17:10,13 17:16 corporation 5:19 counse14:15 13:14 13:17 14:4 19:11 19:14 County1:2,16 3:3 3:4 course11:25 court1:1,18 3:3,7 3:19 5:2,9,21 8:7,24 9:1,16,23 10:6,9,13,14,20 11:1,11 12:4 13:8,12,22,23 14:9,14,17 15:10 15:14,22 16:9 17:5,16,24 18:3 18:13 Courthouse1:16 3:4 Courts5:1 8:21 cracker-jack4:20 created14:25 crime14:16,16 crimes12:2 15:8 criminal9:21 11:1 Crow1:18 3:2 D DATE1:15 Dated19:17 David1:18 3:2 day19:17 decision5:24 5:13 deemedIfl:2 7 Defendants/Cou.. . DEFENDANT/COUN.. . defense9:21 delineated 11:15 DENNEY2:9 deserves7:7 determination 13:25 determinations 8:11,14 determine6:2,9,25 8:18 10:14 15:14 different 7:5 direct4:16 8:5 directed5:9 disagree13:11 discusses10:12 Dixie1:17 3:4 docket 12:6 document 5:10,11 5:18 7:4 8:17,19 documents 4:5,8,9 6:2,14 7:3 8:9 8:13 9:11 10:22 WWW.USLEGALSUPPORT.COM 561-835-0220 EFTA01103143 Page 2 12:12,12 13:1 14:15,24 15:2,13 16:11 17:6,7,9 17:10,14,17,17 doing8:2 E earliest16:16 easier17:2 easiest17:19 Edwardsl:8 11:20 12:5 14:21,25 employee 19:11,13 entire10:12 entries12:6 Epstein1:4 3:8 11:22 12:7 14:14 14:22 17:15 18:11 ESQ2:6,11 essentially4:7 ethical14:18 event15:7 example5:16 7:2 18:8,11 expected4:4 16:21 explain10:18 F faced9:4 12:11,19 16:4 fact 5:16,19,25 6:8 7:17 8:23 11:4 faith5:25 6:14 fear11:18 15:5 federa18:21 10:1 fee15:14 FIFTEENTH1:1 Fifth4:10,24 5:3 6:1,17 7:1,18 8:19 9:5,12 10:15,24 12:13 12:14,23 13:4,16 14:2,5 filed3:10 financial 12:2,3 15:8 financially 19:15 find12:18 finish10:18 first 8:6 Florida1:2,17,24 2:5,10 3:5 19:4 following1:20 follows3:6 forced14:12 foregoing19:6 Fort2:5 forth4:23 7:23 9:2 forward6:8 FPR/RPR19:20 furnished14:17 further6:20,21 16:21 19:10 future11:18 generally4:25 give15:19 18:10 given10:22 12:19 glass18:16 go 17:20 goes6:8 going12:24 13:8 14:9 16:9,10,17 good3:7 5:25 6:14 good-faith6:19 government 11:23 11:24 12:1 14:20 15:9 grounds4:25 5:15 6:1 8:10 guess18:16 HADDAD 2:3,6 happen 7:13 happens7:10 heardi:20 13:13 hearing1:12 3:2 4:14 6:11,21,21 15:21 help15:23 Highway1:17 3:4 Honestly14:11 Honor14:7 18:19 Honorable1:18 3:2 Honor's13:24 hour15:20 hypothetically 9:14 10:21 identifying 12:12 immunity11:2 14:14,22 iRplement13:22 included12:2 including15:7 incriminate 5:19 incriminating 4:2 12:9 independent 4:21 individual5:18 individually 1:8,8 17:21 18:2 information 4:17 4:22 6:12 12:4 initial 8:7 initially3:22 15:9 interested 19:15 internal6:6 interrogatories 9:8 16:20,22,24 ironically 11:13 issue3:17 10:1,1e 12:10 14:13,23 .7 JI:8 JACK2:11 JEFFREY1:4 Judge1:18 3:3,13 ):4,14,18 10:12 10:17 11:16 12:11 15:17 16:1 16:18 17:12 18:1 18:7,18 Judicia11:1 11:4 June1:15 3:5 19:17 jury7:21 K know7:7 14:11 L laid11:9 Lakes 2:10 Lauderdale2:5 law2:3 3:14 4:23 5:21 6:8 9:19,20 11:7 16:23,24 lawsuit14:20 legall:23 4:20 legitimacy5:3 legitimate15:5 lengthy16:13 let's10:22 link14:16 list4:4 littlo17:2 log3:23 4:1 5:7,9 6:7,7 13:4 14:23 long12:6 look5:22,23 6:2 7:6 8:10,13,18 11:17 13:9 16:11 17:20 18:14,15 looking8:16 10:3 101;612:20 lost12:14 lot4:17 15:23 loud7:10 lower9:1 Maged10:4,9 magnifying 18:16 making14:23 March3:15 mean9:16 17:16 mere12:11 method6:18 15:13 methodology 5:2,5 15:13 middlo16:12 mimeographed 18:4 mimeographs 18:5 mine9:25 momentarily 9:10 Monday1:15 15:20 morning3:7 motion3:10,11,12 10:6,7 11:7,15 16:23 move18:13 multiple15:12 N nature17:1 necessarily7:5 17:18 necessary13:22 need6:20 never16:20 non-constituti... 3:24 4:6,13 5:13 7:12 8:10 non-prosecution 11:21 15:4 North1:17 3:4 note17:2 notes19:8 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