Epstein Secrets

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

pursue production of them further solidifies Mr. Epstein's malpractice claims. While approximately 1,600 documents from the disc were identified on Fanner Jaffe's privilege log, because Fanner Jaffe (1) produced some of the documents on its log, (2) expressly agreed to produce gtl work-product documents to Fo

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

issues. DE 6353 at 5-6. This argument does not address the more basic attorney-client privileges, which have never been waived in any way. But, as Fanner Jaffe's briefing clearly explains, there has never been any waiver — either of attorney-client privilege or work-product protection — over the "key emails"

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

orneys 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 EFTA00799314 Case 09-34791-RBR Doc 6323 Filed 03/19/18 Page 2 of 23 Epstein or his legal counsel might misappropriate