Epstein Secrets

that the special master would review the actual documents. So reading the transcript, I believe the procedure Your Honor contemplated was that the Farmer Jaffe firm would have input before any of these documents were OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) 358-8875 EFTA00731404 1 2 3 4 5 6

sert the privilege. And I'm seeing legally some appellate issues with that one. Actually, I think we may end up being in a reversible situation in the State Court on that, if it goes before Appellate Court scrutiny. So I'm concerned at this point legally telling Mr. Edwards and telling Mr. Farmer that they

. 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

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Edwards contends that Epstein'

d deliver to the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Farmer, Jaffe") the documents at issue in the subpoena, giving Farmer Jaffe an opportunity to prepare a privilege log. The order also established a procedure for the Special Master to hold a hearing about assertions of priv

relevance, burdensomeness, and attorney-client and other privileges regarding the Razorback Creditors' subpoena. Instead, these issues are left to the State Court judge presiding over their case to decide. I. BACKGROUND The procedural background surrounding the Razorback Creditor's motion is important to t