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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
rs, which ended up with the order that we're talking about today. Another point of clarification, Mr. Scarola says that the order was entered over Farmer Jaffe's objection. He may have had some -- the law firm may have had some concerns, but it's very clear it's an agreed order. I don't know that that makes
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
have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,
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
s numbering of this large volume of documents be 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
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
ONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fowler White Burnett, P.A. ("Fowler White"), by and through undersigned counsel, hereby responds to Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to
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
OSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess Sanctions and Cost
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
Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffe's Privilege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to i
Entities connected to both Carney and Farmer Jaffe's

Jeffrey Epstein
PERSON
Joe Biden
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Prince Charles
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSON
Bradley Edwards
PERSON
Michael Cohen
PERSONScott Rothstein
PERSON
Condoleezza Rice
PERSONJack Scarola
PERSONDarren Indyke
PERSONJack Goldberger
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONJoseph L. Ackerman
PERSONJaffe
PERSON
Salt Lake City
LOCATIONJane Doe
PERSON