Epstein Secrets

AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fowler White Burnett, P.A. ("Fowler White"), by and through undersigned counsel, hereby responds to Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why Fowl

constitutional authority to address criminal contempt, absent statutory authority.") citing In re Hipp and Walton v Countrywide Homes Loans. While the Eleventh Circuit has recently reviewed a bankruptcy court's ruling imposing both civil and punitive sanctions in In re McLean, 794 F. 3d 1313 (11th Cir. 2015), it di

amping these thousands of documents [DE 1120], ultimately resulting in an order from this Court that Epstein's counsel— attorneys at the law firm of Fowler White Burnett, P.A. ("Fowler White")—would make a copy of the materials and return them to Fanner Jaffe. Because of Fanner Jaffe's obvious concern that 1 EFTA00

pt penalty"); Watkins, 943 F.2d at 1301, 1304 1301; Jaeger v. Massis, No. 00-7390. 2000 U.S. App. LEXIS 27908 (2d Cir. Nov. 3, 2000). Courts within the Eleventh Circuit have not hesitated to impose severe sanctions pursuant to their inherent powers, including cases where a party has acted in bad faith. See, e.g., I

f Justice United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITED STATES ATTORNEY NLIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 11Of II.;•.1.A.111 A. . Igh Re: Jeffrey Epstein Dear Ms. Sanchez: 99 N.E 4 Simi Mann* FL 33132 (305) 961-9I00 • Telephone O0O530-6444 • F

009 WL 2567831, fn. I (E.D. Cal. Aug. 18, 2009). U.S.' Zane, 2009 WL 2567832, fn.l (E.D. Cal. Aug. 18 2009). As to the meaning of "actual damages," the Eleventh Circuit in McMillian i t F.D.I.C., 81 F.3d 1041, 1055 (I I th Cir.1996)3, succinctly explained: 3 In McMillian the I 1th Circuit was faced with the task of