Epstein Secrets

1 Fax: (561) 820-8777 E-mail: [email protected] E-mail: [email protected] Attorneys for the Government Joseph L. Ackerman, Jr. Fowler White Burnett PA 777 S. Hagler Drive, West Tower, Suite 901 West Palm Beach, FL 33401 Criminal Defense Counsel for Jeffrey Epstein (courtesy copy

arguments that the victims had not seen before in the three-and-a-half years that this case has been litigated. The victims then filed under seal a Motion for Court to Deny the Motion to Dismiss Based on Existing Pleadings or, at a Minimum, Allow Leave to File a Sur-Reply. That motion explained that the Governm

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

ndix in Support of Response in Opposition to Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence, and D.E. 1252, Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for 2 EFTA00793756 Additional Limited Discovery, Evidentiary Hearing and

er issues surrounding the 27,000 page disc of e-mails located in Fowler White's files; follow up with client on outcome of hearing; follow up with Fowler White re issues surrounding disc; work on Emergency Petition for Writ of Mandamus and Emergency Motion for Review of Order Denying Stay 03/08/18 K

from Trial Docket in Order to Comply With the Mandate Set Forth in Rule 1.440; work on Response to B. Edwards' Motion for Separate Trials; work on Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery, Evidentiary and Appointment of Special M

ite; communications with co-counsel re filing of same; multiple communications conceming the rescheduling of J. Epstein's, Link & Rockenbach's and Fowler White's depositions; work on Motion for Permission to Unseal Disc and 47 Exhibits to use at bankruptcy evidentiary hearing; provide filings to D.

e J. Epstein's Untimely Supplemental Exhibits and to Strike All Exhibits and Reference to Documents Containing Privileged Materials, and Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, for purposes of drafting Sworn Declaration of Fact of Scott J. Link, as part of Bankr

te; communications with co-counsel re filing of same; multiple communications concerning the rescheduling of J. Epstein's, Link & Rockenbach's and Fowler White's depositions; work on Motion for Permission to Unseal Disc and 47 Exhibits to use at bankruptcy evidentiary hearing; provide filings to D.

e J. Epstein's Untimely Supplemental Exhibits and to Strike All Exhibits and Reference to Documents Containing Privileged Materials, and Epstein's Motion for Court to Declare Relevant and Non-Privileged Nature of Documents, for purposes of drafting Sworn Declaration of Fact of Scott J. Link, as part of Bankr