Epstein Secrets

ards Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 Miami, FL 33131 [email protected] Counsel for Fowler White Burnett, P.A. EFTA00808136 Case 09-34791-R BR Doc 6384 Filed 05/14/18 Page 6 of 6 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Avenue, S

edies as the Court may find just and proper. CONCLUSION The Court should grant the three Victims' the relief requested above, including joinder in Farmer Jaffe's motion for sanctions and their own sanctions and other relief, for reasons as described in DE 6345 and DE 6357, as well as Farmer Jaffe's related pl

erdale. FL 33301 Attorneys for Jeffrey Epstein 11 EFTA00810612 Niall T. McLachlan Carlton Fields Jorden Burt. P A Miami. FL 33131 Counsel for Fowler White Burnett, P.A. 12 EFTA00810613

ry, Epstein did not file any answer or response, even though Epstein had previously filed a detailed Response in Opposition to Bradley Edwards' and Farmer Jaffe's Summaries of Damages for violation of the same order from this Court. See DE 6394. Accordingly, unlike the damages sought by Mr. Edwards which Epste

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

proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d

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

ONS 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 Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to

e Doe Peter E. Shapiro Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, P.A. Isaac M. Marcushamer Counsel for Fowler White Burnett, P.A. Counsel for Liquidating Trustee 13 EFTA00794268

there had been a waiver of any privilege with regard to documents contained on the disc that permitted you to file documents that were included on Farmer Jaffe's privilege log. Ianno (Fowler White's counsel): And I want to add my objection that that has nothing whatsoever to do with the motion, the order or

s for Bradley J. Edwards 10 EFTA00795936 Case 09-34791-RBR Doc 6358 Filed 04/12/18 Page 11 of 12 SERVICE LIST Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976 Scott J. Li

OSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess Sanctions and Cost

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

Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffe's Privilege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to i