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. BY MR. SCAROLA: Q I am going to hand you what I will mark as Exhibit Number 2 to your d

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

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

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

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

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

rned over to them solely for purposes of performing the administrative task of Bates stamping and printing out copies, one to be delivered to Judge Carney, serving as Special Master on behalf of the bankruptcy trustee, and a second copy to go to the Farmer Jaffe law firm, so that a OUELLETTE & NIAULD

laim some of them are privileged. They submitted a privilege log, Mr. Scarola said it was for this Court. It wasn't. The privilege log is in Judge Hafele's court, in the 15th Judicial Circuit in Palm Beach County. OUELLETTE & NIAULDIN COURT REPORTERS, INC. EFTA00787735 1 2 3 4 5 6 7 8 9 1

ged documents; and (iii) prepare a privilege log in accordance with standard practice and law." [DE 888]. 7. On September 20, 2010, Special Master Carney moved for clarification of this Court's order, suggesting that Farmer Jaffe be permitted the opportunity to review the documents themselves in orde

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

12 28:8,16 29:16 31:11 27:25 appeals 21:14 Bates 11:5 12:13,22 CARLTON 2:13 43:14,25 44:5 45:5 actually 29:12 33:13 appear 48:13 13:25 26:8 Carney 12:23 15:4 26:8 clearly 14:20 17:16 40:12 appearance 6:8 47:5 Beach 19:25 25:248:18 26:12,18,23 32:20,21 28:12 addition 44:8 appearances 2:2 3

:16,19 6:17 40:25 43:11 goods 9:23 grant 9:18 31:22 granted 5:2 31:13 47:15,15 guidance 16:7 H Hafele 20:1,6 21:7.12 22:1723:11,16,18 24:1 Hafele's 19:24 21:8 22:14 hand 50:14 Hang 47:21 happen 37:3 happened 22:9 28:4 30:3 34:23 37:2 38:11,12 happy 16:20 hard 12:12 14:14 having 14:142

ver to them solely for purposes of performing the 22 administrative task of Bates stamping and printing out 23 copies, one to be delivered to Judge Carney, serving as 24 Special Master on behalf of the bankruptcy trustee, and a 25 second copy to go to the Farmer Jaffe law firm, so that a 3 (Pages 9 t

of them are 22 privileged. They submitted a privilege log, Mr. Scarola 23 said it was for this Court. It wasn't. The privilege log 24 is in Judge Hafele's court, in the 15th Judicial Circuit 25 in Palm Beach County. Page 18 1 MR. LINK: Judge, if I can just respond 2 briefly on behalf of Mr. Epst

ose the Bates number over those documents and burn the results onto the disk. That's the disk that we returned. We returned original disks to Judge Carney, we have an email to that effect. That disk was then -- well, we produced the, I think, seven bankers boxes of documents to Farmer Jaffe within th

ending -- MR. LINK: The actual --- THE COURT: -- is Edwards versus Epstein for malicious prosecution? MR. LINK: Yes, sir, and that is set on Judge Hafele, the state court's trial docket -- December 4th or 10th? December 4th, specially set. THE COURT: So at the time the -- what was it, 26 boxes of doc