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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
client. And I can say legal counsel, Mr. Goldberger. So that's it." Hearing Trans. 64:14-19. 30. During the hearing, counsel for Epstein (Link and Rockenbach) also revealed that Fowler White was disclaiming any memory of the circumstances surrounding the creation and retention of the disc: "We have reach
cause, for representing then-minor girls sexually abused by Epstein, including L.M. 21. On March 2, 2018, Epstein, through counsel Scott Link and Kara Rockenbach, Epstein filed Plaintiff/Counter-Defendant Jeffrey Epstein's Notice of Filing of Redacted Appendix in Support of Response in Opposition to Defendan
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
ou've done your job." (March 8, 2018, Aft. Tr. 59:1-4.)5 • "So I again want to make clear that I'm finding absolutely no fault with Mr. Link, Miss Rockenbach, Miss Campbell or anyone else from the Link and Rockenbach firm in terms of what they did, albeit in the manner in which they had to do it and the
ties contemplated turning the documents over, work product documents, to Mr. Epstein's lawyer so they would both have a set to argue to Magistrate Carney. The issue with these 47, that Mr. Scarola has said they're attorney-client privilege documents. If they are attorney-client privilege, then they
te-filed exhibits, that most, if not all, of the proposed late-added exhibits were available to Mr. Epstein or his counsel before Mr. Link and Ms. Rockenbach. And they were available either before the previously scheduled December 17th trial date, or the date set earlier this year in March of 2018. I'v
Entities connected to both Carney and Kara Rockenbach

Jeffrey Epstein
PERSON
Donald Trump
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSON
Michael Cohen
PERSON
Bill Clinton
PERSONJack Scarola
PERSONScott Rothstein
PERSON
Eric Trump
PERSONJack Goldberger
PERSON
Condoleezza Rice
PERSONDarren Indyke
PERSON
Alfredo Rodriguez
PERSON
Paul Cassell
PERSON
Marc Rich
PERSON
Woody Allen
PERSON