Epstein Secrets

u ever reviewed the transcripts of any hearings that were held either in the circuit court, in the bankruptcy proceeding, or before Special Master Carney with regard the production of emails? A I don't recall. Q I am going to hand you what I will mark as Exhibit Number 2 to your deposition. It is

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Movants contend that Epstein's

incurred by Jeffrey Epstein, as he was no longer voluntarily willing to pay for the service. While Farmer Jaffe's motion was pending, Special Master Carney contacted Farmer Jaffe about Fowler White's offer to copy and Bates stamp the documents in-house to save Epstein costs. Special Master Camey recomm

so produced containing 3,804 pages of documents in the first box and 3,880 pages of documents in the second box, totaling 7,684 pages. In May 2012, the State Court Judge Crow ordered 163 pages of documents from the February 23, 2011 privilege log be produced and Edwards and Fanner Jaffe complied. The remaining

g and Bates Stamping would be done at Epstein's expense. Farmer Jaffe tried to insist on an outside vendor providing the service, but Special Master Carney and members of the Fowler White law firm convinced the Court that it was more cost-effective for Epstein to perform the task in-house at Fowler Whi

ed the adequacy of Mr. Edwards's privilege log years ago. 6 EFTA00795932 Case 09-34791-RBR Doc 6358 Filed 04/12/18 Page 7 of 12 At one point, the State Court—the only Court with jurisdiction over the adequacy of the log— agreed that the log was insufficient and then before requiring a revised log reversed

rs"). The Razorback Creditors' motion seeks to "clarify" that they have a right to "fully participate" in the process established by Special Master Carney for determining whether internal law firm e-mails and other records are protected by the attorney-client privilege. The motion, however, rests on t

relevance, burdensomeness, and attorney-client and other privileges regarding the Razorback Creditors' subpoena. Instead, these issues are left to the State Court judge presiding over their case to decide. I. BACKGROUND The procedural background surrounding the Razorback Creditor's motion is important to t

0 COURT, m end fel the SOUTHRRN DIST/UCT OF FLORIDA. 21 THE COURT: All right Insofar as the 21 el 799 Ear! Browsed Bad , Fr LatelerdaM/3704444 21 Carney, TIMM on Tondo, Mom 4, 2010, 22 TD Bank motion, Docket Entry 780, that has been the 21 omemendng Mei Mos 9130 ant, se4 the knave% 23 subject matte

1O41O111: Good morning, your Honor, MR. NESVEZTH: — both of whom are MOTE MOTION TO COMP ILPRODUCTTON OF DOCUMENT'S FROM TRUSIta, 12 familiar with the State Court angle on this than 1 12 PURSUANT TO COMMENT PRCOUCTION PROTOCOL BSTABLISHED 13 am, so they came along to be able to elucidate that BY DB0672 (S07),