Epstein Secrets

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

hat Edwards claims are privileged and are currently under seal may be unsealed at the mediation and shown by Epstein's attorneys to the mediator and Fowler White's attorneys. Edwards' counsel shall bring Edwards' copy of the 47 e-mails to the mediation for this limited purpose. 8. The use of the 47 e-mails d

Jaffe who have the full authority to settle without further consultation shall appear at the mediation in person. Furthermore, a representative of Fowler White's insurance carrier who has full authority to settle in an amount up to its policy limits without further consultation shall appear at the mediation i

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

ation with regard to each known policy of insurance, including 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. a

Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRODUCTION Defendant, Bradley J. Edwards, along with Farmer Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a N

d "Epstein Bates Stamp" that Fowler White had in its files and turned over to Link & Rockenbach in February 2018. The Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention.

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

cution case, Farmer Jaffe asserts. On March 7, Epstein's current counsel gave Edwards' counsel a flash drive its said duplicated a disc it found in Fowler White's files and provided a sworn affidavit from a paralegal saying she had obtained the materials from Fowler White's files. According to the motion, dur

MO had ovary rea➢on to 10 12 1 Jaffe, Miming, Edwards, Flacon and Lehrman• -- I believe that this respected is.. firm and these 2 THE COURT: Farmer Jaffe, right? 2 respected lawyers would do exactly what they were 3 MR. SCAROLA: Yes. Pinner Jaffe. 3 told to do. 4 THE COURT: Be can just refer co

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

MO had ovary rea➢on to 10 12 1 Jaffe, Miming, Edwards, Flacon and Lehrman• -- I believe that this respected is.. firm and these 2 THE COURT: Farmer Jaffe, right? 2 respected lawyers would do exactly what they were 3 MR. SCAROLA: Yes. Pinner Jaffe. 3 told to do. 4 THE COURT: Be can just refer co

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

. 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

received select documents from the disc in February 2018. The select documents were provided to Epstein after Link & Rockenbach located the disc in Fowler White's boxes in February 2018. Because there are no material facts in dispute, live testimony will have no impact on this Court's determination of whether

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

xhibits (the "47 e- v mails") that Edwat*elaims are privileged and are currently under seal may be shown by Edwards' attomeys,only to the mediator, Fowler White's attorneys and Fowler White's insurance carrier represe tpiv . Edwards' counsel shall bring Edwards' copy of the 47 e-mails to the mediation for O

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

e 09-34791-RBR Doc 6441 Filed 09/04/18 Page 2 of 5 further consultation shall appear at the mediation in person. In addition, a representative of Fowler White's insurance carrier who has full authority to settle in an amount up to its policy limits without further consultation shall appear at the mediation i

categories, I think you called them, of documents irrelevant, attorneys' eyes only, those were documents that were hard copies received back from Farmer Jaffe by Fowler White, to your knowledge? MR. IANNO: Object to the form. THE WITNESS: That's my understanding. BY MR. EDWARDS: Q And then there were

was reviewing the emails for that, you know, I may have a recollection of it, as I mentioned right now. BY MR. EDWARDS: Q Was there anything in Fowler White's possession that you knew was something that was written -- handwritten by Special Master Carney? A I don't recall seeing anything that I knew fo