Epstein Secrets

ommunications of Edwards as an administrative convenience to him in developing a privilege log, but would not maintain any copies: Mlle 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 docu

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel hereby certify that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

g him not to answer, if it's based on our communications period. BY MR. SCAROLA: Q The second paragraph of this affidavit says, "The law firm of Fowler White Burnett, PA represented me" -- meaning you -- "in the state court proceeding from June 2010 through May 2012." What were the terms on which you retained

urt matter. MR. SCAROLA: We are. MR. LINK: I may have misunderstood, because this is a bankruptcy declaration. And there isn't anything in Judge Hafele's order that talks about bankruptcy testimony or spoke that you can inquire about. Obviously, by signing this he has adopted every statement in t

m from a disc that we started reviewing on February 25th, 2018? I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

ng him not to answer if it's based on our communications period. BY MR. SCAROLA: Q The second paragraph of this affidavit says, "The law firm of Fowler White Burnett, PA, represented me" -- meaning you -- "in the state court proceeding from June 2010 through May 2012." What were the terms on which you retained

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

ourt matter. MR. SCAROLA: We are. MR. LINK: I may have misunderstood, because this is a bankruptcy declaration. And there isn't anything in Judge Hafele's order that talks about bankruptcy testimony or spoke that you can inquire about. Obviously, by signing this, he has adopted every statement in

ng him not to answer if it's based on our communications period. BY MR. SCAROLA: Q The second paragraph of this affidavit says, "The law firm of Fowler White Burnett, PA, represented me" -- meaning you -- "in the state court proceeding from June 2010 through May 2012." What were the terms on which you retained

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

else did he tell you? MR. LINK: So, I'm going to instruct you not to answer based both on attorney- client privilege and exceeds the scope of Judge Hafele's order. I" Epstein Depo. Tr. at 22. Clearly Epstein put forward the conversation with his attorney about the disc in paragraph four of his declara

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

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

Fowler White Burnett ATTORNEYS AT LAW Miami I Fort Lauderdale I Palm Beach November 30, 2018 Scott J. Link, Esquire LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd

s pursuit of these issues at the time of its termination by your client more than six (6) years ago. In reviewing your selected excerpts from Judge Hafele's statements, it is clear you are attempting to place a context which the Court did not intend. Judge Hafele was upset that he was being asked to lo

d Order that was entered by the Bankruptcy Court on November 30, 2010. The November 2010 Agreed Order provides, in pertinent part: The law firm of Fowler White Burnett, P.A., will print a hard copy of all of the documents contained on the discs with Bates numbers added, and EFTA00793680 Niall McLachlan Joseph I

s and costs in his defense of those claims. In addition, when we identified several key case-ending e-mails from the disc as trial exhibits, Judge Hafele struck those exhibits as untimely. Furthermore, Judge Hafele did not want to make any rulings in derogation of the Bankruptcy Court's Order if Fowle

orneys for Bradley J. Edwards Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. 13 EFTA00795957 Case 09-34791-RBR Doc 6357 Filed 04/12/18 Page 14 of 14 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Aven

ADMITTED THAT HE POSSESSED DOCUMENTS FROM THE DISK IN QUESTION Epstein has previously admitted in the related state court proceedings before Judge Hafele that he possessed documents from the disk in question. Now, before this Court, he appears to take a different position. For example, Epstein states