Epstein Secrets

ge Ray that impose restrictions on the possession of electronic data produced in response to a subpoena for emails from the Rothstein, Rosenfeldt, Adler law firm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793426 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 27 of 97 1 2 3 4 5

Did you ever learn that privilege was being asserted with respect to the production of any emails that were contained on a Rothstein, Rosenfeldt, Adler server? A Separate from a conversation with my attorneys, I don't recall. Q Are you aware, as you sit here today, that federal bankruptcy Judg

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

ourt matter. MR. SCAROLA: We are. MR. LINK: I may have misunderstood, because this is a bankruptcy declaration. And there isn't anything in Judge Hafele's order that talks about bankruptcy testimony or spoke that you can inquire about. Obviously, by signing this, he has adopted every statement in

ge Ray that impose restrictions on the possession of electronic data produced in response to a subpoena for emails from the Rothstein, Rosenfeldt, Adler law firm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793528 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 31 of 165 2 3 4 5 6

Did you ever learn that privilege was being asserted with respect to the production of any emails that were contained on a Rothstein, Rosenfeldt, Adler server? A Separate from a conversation with my attorneys, I don't recall. Q Are you aware, as you sit here today, that federal bankruptcy Judg

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I think that's a legitimate question, pursuant to both -- well, pursuant to Judge Hafele's order, not pursuant to the bankruptcy order. But your question hasn't been tailored that way. MR. SCAROLA: And that's because that's not the q

else did he tell you? MR. LINK: So, I'm going to instruct you not to answer based both on attorney- client privilege and exceeds the scope of Judge Hafele's order. I" Epstein Depo. Tr. at 22. Clearly Epstein put forward the conversation with his attorney about the disc in paragraph four of his declara

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:16,19 6:17 40:25 43:11 goods 9:23 grant 9:18 31:22 granted 5:2 31:13 47:15,15 guidance 16:7 H Hafele 20:1,6 21:7.12 22:1723:11,16,18 24:1 Hafele's 19:24 21:8 22:14 hand 50:14 Hang 47:21 happen 37:3 happened 22:9 28:4 30:3 34:23 37:2 38:11,12 happy 16:20 hard 12:12 14:14 having 14:142

to rest once and for all. A. Negligent Retention of Disc During its representation, Fowler White pursued production from the Rothstein Rosenfeldt Adler firm's ("RRA") Bankruptcy Trustee in response to a Subpoena served by the Burman Critton firm. The Trustee assembled approximately 27,000 pages of e

s and costs in his defense of those claims. In addition, when we identified several key case-ending e-mails from the disc as trial exhibits, Judge Hafele struck those exhibits as untimely. Furthermore, Judge Hafele did not want to make any rulings in derogation of the Bankruptcy Court's Order if Fowle

language is imprecise, but what I am trying to point out is that these emails are part of the emails that originated on the Rothstein, Rosenfeldt, Adler servers. They were, that electronic data, was transferred to compact disks. The compact disks were used to print out emails, including those that

tiff/Counter-Defendant Epstein's Motion to Allow Amendment to Exhibit List, et al. The above-styled cause came on for hearing before the Honorable Donald W. Hafele, Presiding Judge, at the Palm Beach County Courthouse, West Palm Beach, Palm Beach County, Florida, on the 2nd day of November, 2018. Palm Beach

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25 them, if you want to get them, go to that SUSAN S. WIGGINS. R.P.R. and OFFICIAL COURT REPORTER EFTA00232530 14 1 case, that would be Judge Hafele or two of 2 Mr. Edwards' cases are where is Mr. Kuvin's 3 case is or Judge Marra, where Mr. Edwards' 4 case is. Judge Marra can certainly contr

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specific tangible need arises in a civil case the relief should be sought in that case.' In other words, the Civil cases which are in front of Judge Hafele is one forum that Judge Marra said go to it. Judge Marra did not say that this Court does not have Jurisdiction to unseal its own sealed records or