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

ite Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976 Scott J. Link, Esq. Link & Rockenbach, P.A. Scott @linIcrocklaw.com [email protected] 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401

g excess or umbrella insurance, that would cover any claim that has or may result from Fowler White's retention of documents and/or a disc that (1) Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., (2) Bradley J. Edwards, and (3) L.M., E.W. and Jane Doe have alleged were improperly retained: a. The

e policy(ies). Please provide this information within 30 days as required by the statute. Thank you for your attention to this matter. Sincerely, Scott J. Link SJUtic EFTA00805156

and its insurer, (4) Intervenors Jane Doe, L.M. and E.W. (collectively, "Intervenors"), and (5) Farmer Jaffe Weissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Mediation Participants"), to participate in mediation subject to this Agreed Mediation Confidentiality Order. The Court, here

fendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 Trial Counsel for Plaintiff/Counte

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

te 4200 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. Counsel for Liquidating Trustee Scott J. Link Chad P. Pugatch Kara Berard Rockenbach Link & Rockenbach, PA Rice Pugatch Robinson Storfer & Cohen, PLLC 101 N.E. Third Avenue, Suite 1800 1555

rivileged materials for over seven years," Fanner Jaffe said in its motion. "The misappropriation of this information has caused irreparable harm." Farmer Jaffe filed its motion in bankruptcy court in Fort Lauderdale, Florida, in the liquidation case of law firm Rothstein Rosenfeldt Adler PA, where Edwards h

sing Edwards Fistos & Lehrman PL is represented by Bradley J. Edwards and Brittany N. Henderson of Edwards Pottinger LLC. Epstein is represented by Scott J. Link and Kara Rockenbach of Link & Rockenback PA and Jack A. Goldberger of Atterbury Goldberger & Weiss PA. Edwards is represented by Jack Scarola and D

Jaffe Weissing Edwards Fistos & Lehrman PL had said in a March 19 motion that recent developments in ongoing litigation between Epstein and former Farmer Jaffe partner Bradley J. Edwards, who represented several of Epstein's victims, showed that Fowler White retained a copy of confidential documents and th

sing Edwards Fistos & Lehrman PL is represented by Bradley J. Edwards and Brittany N. Henderson of Edwards Pottinger LLC. Epstein is represented by Scott J. Link and Kara Rockenbach of Link & Rockenback PA and Chad P. Pugatch of Rice Pugatch Robinson Storfer & Cohen PLLC. Fowler White Burnett PA is represent

. 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

requests to be excused from personally attending the Show Cause hearing. Epstein will be represented at the hearing by his counsel, Chad Pugatch and Scott J. Link. ARGUMENT A. What Happened to the Disc in 2018 is Not a Violation of This Court's November 2010 Agreed Order. The Court was clear that issues re

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

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 Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 S' * Trial Counsel for Plaintio7C

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

5 EFTA00795924 Case 09-34791-R BR Doc 6418 Filed 08/10/18 Page 6 of 7 SERVICE LIST Joseph L. Ackerman, Jr., Esq. Fowler White Burnett. P.A. Scott J. Link, Esq. Link & Rockenbach, P.A. ttorneys for Jeffrey Epstein Jack A. Goldberger, Esquire [email protected]; [email protected] • , P.A. 1400

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

drews Avenue, Suite 2 Fort Lauderdale. FL 33301 Phone: (954)-524-2820 Fax: Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Scott J. Link, Esq. Link &Rockenbach, PA. 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Jac