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k at the Fowler White files. Then there's 24 THE COURT: That was the litigation lad by :4 a two-week delay between looking at the Fowler 25 Mr. Scherer. ,5 White files and receiving the disk. Md then Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793837 17 19 I there's a tam-weak dela
114:6 114:12,15,24 115:8,20 116:18 117:6,9 118:1 119:15,24 Scarola's 36:9 scheduled 6:7 schedules 119:20 scheduling 43:22 scheme 17:9 95:9 Scherer 14:25 15:2 15:3,9,1018:18 18:20 19:2,11 Scope 3:12,17 score 94:1 I Scott 1:8 2:5 38:19 39:20 57:7 113:9 scrambling 73:4 screen 56:8 screenin
RE II Deoksbor 5th and nide it clear to all parties that 10 12 exhibits that. here net disclosed by the end of II For Non-Parties L.M., E.M. 4 Jana Doe 22 1a Deoabor -- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were no
k at the Fowler White files. Then there's 24 THE COURT: That was the litigation lad by :4 a two-week delay between looking at the Fowler 25 Mr. Scherer. ,5 White files and receiving the disk. Md then Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793790 17 19 I there's a tam-weak dela
114:6 114:12,15,24 115:8,20 116:18 117:6,9 118:1 119:15,24 Scarola's 36:9 scheduled 6:7 schedules 119:20 scheduling 43:22 scheme 17:9 95:9 Scherer 14:25 15:2 15:3,9,1018:18 18:20 19:2,11 Scope 3:12,17 score 94:1 I Scott 1:8 2:5 38:19 39:20 57:7 113:9 scrambling 73:4 screen 56:8 screenin
question in front of you sight now is • very brief, representing three victims; LH, EM and • what to do about this. Well, we knee one thing. • Jane Doe. /Vat ono housekeeping natter. s lie know there's been absolutely no waiver of 10 No have riled a notion to intervene, which is 10 attorney/cl
November of 23 2009. 24 Q Approximately 18 months -- about year and a 25 half? represented another law firm in a breakup of firma 2 And the Scherer firm waa owed over a million 4 5 4 7 • In Coos. And the client, the other law firm, was reneging on paying that. And Scherer won at the tria
even though the offices I worked II before you would file it, right? 12 out of wore in Miami. And I have heard of the Conrad 12 A Right. 13 Scherer firm throughout my practice. II Q Would you note every single fact that 14 4) You said one of the things in your direct 14 existed at the tim
riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc
GGETT,ROBERT G MARSHALL CARNEY,LISA SCHEERER,JOSEPH SULLIVAN,CHARLES W DE TULLIO
QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL
stein and Edwards' law firm of which he was a partner. Despite this, Edwards voluntarily produced documents that he now claims are privileged to Mr. Scherer in the Razorback litigation. Florida law clearly demonstrates that this voluntary production constituted a waiver. Because Edwards and the Razorbac
documents waived the privilege. § 90.507, Fla. Stat. (2006). Id. Notably, Edwards is already familiar with this basic principle. Specifically, in Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014), it was Edwards who argued that the United States failed to confer with his clients before en
hat the Epstein case was a real case and ultimately invested money. A copy of the transcript of this hearing is attached hereto as Exhibit "3". Mr. Scherer's remarks appear on pages 17-22.2 On August 13, 2010, Bankruptcy Judge Raymond Ray ordered in response to a subpoena from Epstein the appointment of
et 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN D
hat the Epstein case was a real case and ultimately invested money. A copy of the transcript of this hearing is attached hereto as Exhibit "3". Mr. Scherer's remarks appear on pages 17-22.2 On August 13, 2010, Bankruptcy Judge Raymond Ray ordered in response to a subpoena from Epstein the appointment of
et 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN D
ule applies here. On March 8, 2018, Edwards' counsel, Jack Scarola, implied (incorrectly) that the e-mails were shared with Epstein's counsel by Mr. Scherer, counsel for Razorback. Thus, Edwards admits that he voluntarily furnished the e-mails to Mr. Scherer. Razorback sought these allegedly privileged
in reliance on Edwards' previous waiver and agreement to produce the same, these e-mails must be deemed not protected by Edwards' clear waiver. See Jane Doe No. I v. United States, 749 F.3d 999 (11th Cir. 2014)(held that Epstein's former counsel had waived the work-product privilege with respect to docum
Funding, LLC, et al. v. Scott W Rothstein, et al., Case No. 09-062943 ("Razorback Complaint"), on behalf of some of the Pont scheme investors. Mr. Scherer asserted the following in the Razorback Complaint at pages 16-17 regarding the Epstein cases: In certain instances, the purported settlements, albe
ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla
hat the Epstein case was a real case and ultimately invested money. A copy of the transcript of this hearing is attached hereto as Exhibit "3". Mr. Scherer's remarks appear on pages 17-22.2 On August 13, 2010, Bankruptcy Judge Raymond Ray ordered in response to a subpoena from Epstein the appointment of
et 09/02/2010 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN D
Entities connected to both Scherer and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
George W. Bush
PERSONRobert D. Critton
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Salt Lake City
LOCATIONScott Rothstein
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATIONJack Scarola
PERSON