Epstein Secrets

cy Judge Raymond B. Ray of the U.S. Bankruptcy Court of the Southern District of Florida entered an explicit order that Epstein's attorneys (at the Fowler White law firm) would merely print out thousands of protected communications of Edwards as an administrative convenience to him in developing a pri

Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I JA LL Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): 644 Cesery Blvd. #250 Jacksonville, FL 32211 And By: /s! Paul G. Cassell PAUL G. CASSELL S.J. Qui

Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention. A show cause hearing is currently scheduled before the Bankruptcy Court on August 23 and 24, 2018. The Bankr

[email protected] Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe 2067547 5 EFTA00805487

ng Show Cause hearing because Edwards is entitled to cross- examine Epstein on the recent discovery that not only did the disc not "sit in a box" but Fowler White printed at least 32 pages of materials from the disc (26 of which are listed in Edwards' privilege log) and made handwritten notations on at

BR Doc 6487 Filed 10/22/18 Page 7 of 12 Fax: (954)-524-2822 Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jay Howell Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell S.J.

in any copies of the documents contained on the discs provided to it, nor shall any images or copies of said documents be retained in the memory of Fowler White's copiers. Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherw

BR Doc 6382 Filed 05/14/18 Page 7 of 7 Fax: (954)-524-2822 Attorneys for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jay Howell Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell S.J.

l ruling on March 8, 2018, incorrectly asserting that the Court prohibited Epstein from referring, in any way, to the 27,000+ pages contained on the Fowler White CD. His claim is that Epstein violated this Court's ruling the four times Epstein "referenced" the documents at issue in one filing with this

ffrey Epstein Paul Cassell 383 S. University Salt Lake Cit UT 84112-0730 Limited Intervenor Co-Counsel for M , E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for n, E.W. and Jane Doe 14 EFTA00808685

this Court's verbal ruling on March 8, 2018, asserting that Epstein was prohibited from referring, in any way, to the 27,000+ pages contained on the Fowler White CD. His claim is that Epstein violated this Court's ruling the four times Epstein "referenced" the documents at issue in one filing with this

effrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe 14 EFTA00808671

n of privilege has ever been made. In addition, the Bankruptcy Court has already issued an Order to show cause allowing discovery focused on whether Fowler White and/or Epstein violated the November 2010 Agreed Bankruptcy Order. Moreover, this Court has ruled that at this point, the 47 exhibits are not

Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for.", E.11" and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for I f f , E. W. and Jane Doe 9 EFTA00808694

ter or otherwise, the court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards or his client." The bankruptcy court permitted Fowler White access to the electronic data because the firm could make the copies and number the documents without reviewing the contents, and this avoided

nhart & Shipley PA and Phil Burlington and Nichole J. Segal of Burlington & Rockenbach PA. L.M., E.W. and Jane Doc arc represented by Jay Howell of Jay Howell & Associates and Paul G. Cassell of Hatch James & Dodge PC. EFTA00793764 The case is In Re: Rothstein Rosenfeldt Adler PA, case number 09-34791, in the U.S. B

ake [sic] to record will be permitted to be filed under seal. (3/8/18 Aft. Tr. 75:16-18.) The Court directed the Link & Rockenbach firm to maintain Fowler White's original files (including the original disc). (3/8/18 Aft. Tr. 80:8-81:15.) 5. Because the case was stayed on March 9, 2018, by the Fourth

te 1400 0730 ' II Limited Intervenor Co-Counsel for LM., E.W. and Jane Doe o- ounse or • ainti i. ounter-Defendant Jeffrey Epstein Jay Howell Jay Howell & Associates ., Suite 250 32211 Limited Intervenor Co-Counsel for LM., E.W. and Jane Doe 5 EFTA00793753 EXHIBIT A EFTA00793754 IN THE CIRCUIT COURT OF

urt. The Evidentiary Hearing Should Be Rescheduled i. Depositions The Show Cause Order permits Edwards to take the deposition of Jeffrey Epstein, Fowler White, and Link & Rockenbach with regard to "the allegations of federal civil contempt regarding the alleged discovery violations of the Agreed Ord

925 Case 09-34791-R BR Doc 6418 Filed 08/10/18 Page 7 of 7 Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jay Howell Jay Howell & Associates Florida Bar No. Attorney E-Mail(s) Paul G. Cassell S.J. Quinney College of Law at the University of Utah (above for address purposes only) Att