Epstein Secrets

7,000 emails and the creation of a privilege log, which has been rendered meaningless due to the violation; this task required the time of numerous Farmer Jaffe employees and in total well over 100 hours of time. Fanner Jaffe seeks reimbursement for only a fraction of that time: 40 hours of attorney time at

EMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS AND FOR OTHER APPROPRIATE RELIEF Farmer Jaffe Weissing Edwards Fistos & Lehrman ("Farmer Jaffe"), through counsel, hereby files this Summary of Damages in Support of Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Sho

ates 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. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 (above for address purposes only) Attorney E-Mail: [email protected]

all claims for all forms of damages, including compensatory damages, sanctions, punitive damages, prejudgment interest, costs and attorneys' fees. Farmer Jaffe, Edwards, L.M., E.W., Jane Doe and Epstein will each bear their own attorneys' fees and costs. Dated: , 2018. Respectfully submitted, EDWARDS PO

ue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell Peter E. Shapiro S.J. Quinney College of Law at the University of Shapiro Law Utah 332 S. University St. 8551 West Sunrise Boulevard, Suite 3000 Plantation, FL 33322 12-0730 Counsel for L

. EFTA00794246 There are no disputed facts material to this show cause proceeding regarding Epstein. The Movants in these show cause proceedings (Farmer Jaffe, Bradley J. Edwards and L.M.) have acknowledged that Epstein did not have the disc or even know of the disc's existence before being advised by Lin

Brittany N. Henderson Edwards Pottinger LLC e, Suite 2 301-3268 ounse or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Sha iro Law uite 3000 Counsel for L.M., E.W. and Jane Doe Counsel for L.M., E.W. and Jane Nia

dwards"), (2) Jeffrey Epstein ("Epstein"), nors Jane Doe, M t and= (collectively, "Intervenors"), and (4) F' eissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Me cipants"), to participate in mediation subject to this Agreed Mediation Confidenti The Court, hereby ORDERS AND ADJU fo

P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell ' S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Ci UT 84112-073 tifi , j thiailed Intervenor Co-Co o and Jane Doe O Scott J. Link

esponses and Objections to the Notices of Taking Video Deposition Duces Tecum of Epstein [DE 6388]. Apparently, their position is that Edwards (and Farmer Jaffe and the Intervenors) are limited to deposition testimony only and have no ability to test the credibility of that sworn testimony through impeachmen

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) Attorney E-Mail: Attorneys for L.M., E.W., and Jane Doe EFTA00795926

ive an opportunity to take discovery (in the form of interrogatories, requests for admission and production, as well as depositions as requested by Farmer Jaffe) on this important subject. 3. A DIRECTION THAT EPSTEIN WRITE A LETTER OF APOLOGY IS APPROPRIATE. The Victims have also requested that Epstein (a

CERTIFY that the undersigned attorney is appearing pro hac vice in this matter pursuant to court order dated April 3, 2018. Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 (above for address/contact purposes only, not