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

th the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). EDWARDS POTTINGER LLC Bradley J. Edwards FLBN 54207 Brittany N. Henderson FLBN 118247 Edwards Pottinger LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Attorneys for Fa

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

stein will each bear their own attorneys' fees and costs. Dated: , 2018. Respectfully submitted, EDWARDS POTTINGER LLC Bradley J. Edwards FLBN Brittany N. Henderson FLBN 425 N. Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Phone: ax: EFTA00806689 SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart &

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

Burlington, Esq. Nichole J. Segal, Esquire ppellateLaw.com Attorneys for Bradley J. Edwards EDWARDS POTTINGER LLC Bradley J. Edwards FLBN 54207 Brittany N. Henderson FLBN 118247 EFTA00795925 Case 09-34791-R BR Doc 6418 Filed 08/10/18 Page 7 of 7 Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,

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

ors.., M, and Jane Doe 12 EFTA00795956 Case 09-34791-RBR Doc 6357 Filed 04/12/18 Page 13 of 14 SERVICE LIST Bradley J. Edwards FLBN 542075 Brittany N. Henderson FLBN 118247 Edwards Pottinger LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 Phone: (954)-524-2820 Fax: Attorneys for Farmer, Jaffe, Weis