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t, but we have been informed that that disk was included in one of 36 boxes that were reviewed by the law firm of Link & Sartory, obtained from the Fowler White law firm, who were predecessor counsel to Mr. Epstein, and were the direct object of this Court's order prohibiting retention of that specif
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
bout discovery, and your Honor said we're not getting into all of that, you can have two depositions. You can depose Mr. Epstein and you can depose Fowler White's corporate representative on very limited issues, and that was, chain of custody of the disk, and the alleged violation of the agreed order
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,
Mr. Epstein money. As is evident by the email correspondence between and amongst the Counsel handling this issue at the time—representatives of the Fowler White firm, the Farmer Jaffe firm, and Special Master Carney—Farmer Jaffe vehemently objected to this Fowler White in-house printing process. In fa
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
included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a duplicate of what was delivered to the Special Master and Fanner Jaffe pu
proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d
Epstein's co-counsel contacted Fowler White and inquired about any confidentiality orders concerning the CD, counsel was specifically told that the Fowler White attorney could not specifically remember due to the age of the file, but that he thought there was such an order and that Epstein's counsel sh
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
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
there had been a waiver of any privilege with regard to documents contained on the disc that permitted you to file documents that were included on Farmer Jaffe's privilege log. Ianno (Fowler White's counsel): And I want to add my objection that that has nothing whatsoever to do with the motion, the order or
Entities connected to both Fowler and Farmer Jaffe's

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONScott Rothstein
PERSONJane Doe
PERSON
Paul Cassell
PERSON
George W. Bush
PERSONJack Goldberger
PERSONJack Scarola
PERSONDarren Indyke
PERSONJoseph L. Ackerman
PERSONFISTOS & LEHRMAN
ORGANIZATIONthe Southern District
LOCATIONFowler White's
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONBates
PERSON
Scott J. Link
PERSON
Fowler White Burnett
ORGANIZATION
Joe Biden
PERSON
Weissing
PERSON