Epstein Secrets

sociates Florida Bar No.: 225657 Attorney E-Mail(s): 644 Cesery Blvd. #250 Jacksonville, FL 32211 And By: /s! Paul G. Cassell PAUL G. CASSELL S.J. Quinney College of Law at the University of Utah 383 S. University St. 84112 casse p aw.uta .edu Utah Bar #6078 Admitted in Proceedings Below/Pro Hac Vice To Be Filed

n any copies of the documents contained on the discs provided to it, nor shall any images or copies of said documents be retained in the memory of Fowler White's copiers. Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherwise, the

ates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 (above for address purposes only) Attorney E-Mail: [email protected]

Order did not "sit in a box" for the past eight (8) years. This fact, however, was only uncovered at the October 19, 2018 deposition duces tecum of Fowler White's corporate representative, which was conducted after Epstein's deposition on October 13, 2018. Thus, the Court should not excuse Epstein from attend

425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer Ja,ffe, Weissing, Edwards, Fistos & Lehrman, a Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 casse11p08aw.utah.edu Peter E. Shapiro Shapiro Law 8551 West

ts on a disc, not sexual abuse claims. Simply, the Intervenors seek money damages for significant emotional distress because a disc sat in a box in Fowler White's files for eight years. Because the Intervenors appear to have failed to present this Court with requisite proof of their damages, this Court can eit

s Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC °tense or anner a e, ersstng, cards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Shapiro Law uite 3000 ounse or ., . . an ane Doe Counsel for L.M., E.W. and Jane Niall T. M

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

n & Rockenbach, P.A. Attorneys for Bradley J. Edwards Jay Howell Jay Howell & Associates Attorneys for L.M., E.W., and Jane Doe Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for L.M., E.W., and Jane Doe EFTA00793678

in its capacity as legal counsel to Jeffrey Epstein. Any violation that occurred with respect to Jeffrey Epstein individually is as a consequence of Fowler White's wrongdoing. The moving parties are therefore dropping the Motion for Contempt against Jeffrey Epstein in order to focus the attention where it is m

rvice list below. SERVICE LIST Jack Scarola Sears Denn , Scarola, Barnhart & Shipley, P.A. yard Counsel for Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for LM., E.W. and Jane Doe Chad Pugatch, Esq. Bradley J. Edwards Brittany N. Henderson Edwards Pottin er LLC

. Movants request sanctions against Fowler White, a law firm which withdrew from representing any party in this case nearly six years ago. DE 3034. Fowler White's investigation has not revealed how the offending CF ended up in its files since it sent the disk back to Special Master Carney after printing the do

s Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC ounse or armer a e, eissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of h Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Sha.iro Law Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan

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

ittany N. Henderson Edwards Pottinger LLC ue, Suite 2 3301-3268 ounse or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton F

hat request. (D.E. 6325; D.E. 6345.) Movants allege that Fowler White EFTA00794256 and Epstein violated this Court's November 2010 Agreed Order by Fowler White's alleged retention of a copy of a disc that was provided to Epstein and his current counsel (Link & Rockenbach) in 2018. (D.E. 6326 at 6-11.) The No

Brittany N. Henderson Edwards Pottinger LLC e, Suite 2 301-3268 ounse or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Sha iro Law uite 3000 Counsel for L.M., E.W. and Jane Doe Counsel for L.M., E.W. and Jane Nia

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

P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell ' S.J. Quinney 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

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