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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
: Cassell is C-a-s-s-e-I-1. 5 THE COURT: And who are you representing in 6 this matter? 7 MR. CASSELL: I represent putative 8 intervenors L.M., E.W. and Jane Doc, who have a pending 9 motion for leave to intervene. 10 THE COURT: All right. Let me ask, is there 11 any opposition to the motion
present in the courtroom? 14 MR. EDWARDS: Your Honor, I was informed 15 that Mr. Paul Cassell was to call into this hearing on 16 behalf of L.M., E.W. and S.R. 17 THE COURT: I don't --- 18 MR. EDWARDS: I don't know what arrangements 19 he made. 20 THE COURT: No such arrangements were made. 21
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
r Shapiro present in the courtroom? MR. EDWARDS: Your Honor, I was informed that Mr. Paul Cassell was to call into this hearing on behalf of L.M., E.W. and S.R. THE COURT: I don't MR. EDWARDS: I don't know what arrangements he made. THE COURT: No such arrangements were made. So, we'll just -- on
R. CASSELL: Cassell is C-a-s-s-e-1-1. THE COURT: And who are you representing in this matter? MR. CASSELL: I represent putative intervenors L.M., E.W. and Jane Doe, who have a pending motion for leave to intervene. THE COURT: All right. Let me ask, is there any opposition to the motion to interve
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
CARLTON FIELDS, BY NIALL McLACHLAN, Esquire On behalf of Fowler White Barnett, P.A. PAUL G. CASSELL, Esquire (via telephone) On behalf of L.M., E.W. and Jane Doe EDWARDS POTTINGER, by BRITTANY HENDERSON, Esquire On behalf of Farmer Jaffe Weissing ALSO PRESENT ECRO - Electronic Court Reporting
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
J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Shapiro Law uite 3000 ounse or ., . . an ane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt P.A. 200 °rinse or ow er nr e urnett, P.A. Isaac M. Marcushamer Ber er Sin erman LLP C
go. DE 3034. Fowler White's investigation has not revealed how the offending CF ended up in its files since it sent the disk back to Special Master Carney after printing the documents per the Court's order. Notwithstanding the uncertainty regarding how the CD got into Fowler White's files, one thing i
e any detail—much less an unequivocal command—as to what Fowler White is to do with the disc at issue. INTRODUCTION AND BACKGROUND Although L.M., E.W., and Jane Doe have sought to join in the motion for order to show cause, they have not been granted leave to intervene in this action. The motion to
e two sets of hard copy documents that were bate stamped. This uncontroverted testimony demonstrated that the "disc" was created for Special Master Carney and not for Fowler White or Epstein. The disc was made because, according to Lilly Sanchez, Special Master Carney did not want 27,542 bate stamped p
ls are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and d
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
to have dealt with this issue head on because of the apparent implications of same." Hearing Trans. at 60:20-61:14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to. Judge Hafele indicat
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
ractice in this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By: /s/ Peter E. ha it Peter E. Shapiro (FBN Attorneys for Intervenors L.M., E.W., and Jane Doe 10 EFTA00793508 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 11 of 165 Attorneys for Jeffrey Epstein SERVICE LIST Bradley J
Entities connected to both Carney and E.W.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSON
Donald Trump
PERSONJack Goldberger
PERSONMaria Farmer
PERSONJane Doe
PERSONLeon Black
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Prince Andrew
PERSONJack Scarola
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Prince Charles
PERSON
Department of Justice
ORGANIZATION
Paul Cassell
PERSON