Epstein Secrets

ed over by them to Link & Rockenbach? A. No. Not to the best of my knowledge. Q. Have you ever communicated with Tonja or Fred Haddad about the Fowler White disc? A. Not to the best of my knowledge. Q. Did you ever receive a copy of the disc itself? A. No. 5 EFTA00793405 Case 09-34791-RBR

the issue of his knowledge and possession of the disc. (Apr. Tr. 36:2-9.) The Show Cause Order also provided for the filing of sworn declarations. (D.E. 6366,91 5 i.v.) Specifically, it provides: Unless otherwise ordered, the direct testimony of each witness, except adverse, hostile or rebuttal witn

ain 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 otherwi

urt orders or rules, or to prevent an abuse of process. The Court has jurisdiction here because the Court retained jurisdiction in the Agreed Order [D.E. 1194], and this alleged discovery violation is a core proceeding. See 28 U.S.C. § 157 ("Core proceedings include, but are not limited to (A) matter

h. (Apr. Tr. 42:1-12.) The Court also allowed the deposition of a representative of Fowler White to explain under oath and to answer the question if Fowler 'The April 13, 2018, hearing transcript (D.E. 6367) shall be referred to as "Apr. Tr." 2 EFTA00794257 White retained any copies in its computers

uly 20, July 25 and September 26, 2018, Edwards filed Notices of Taking Link & Rockenbach's deposition duces tecum. (D.E. 6390; D.E. 6391; D.E. MOO; D.E. 6406; D.E. 6468.) Epstein filed his Responses and Objections on July 20 and October 4, 2018. (D.E. 6402; 6478.) In his Response, Epstein objected t