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te disk containing all the confidential materials..." (Joinder, p. 3). There is no dispute that the documents maintained on a disc transferred from Fowler White are eight years old. There is further no dispute that Edwards and Cassell are fully aware of the documents contained on the disc — they claim the c
xists, and the information finds its light of truth in a court. Until then, the documents are under seal and the "no dissemination" ruling by Judge Hafele has been fully complied with by Epstein and his counsel. The Record Truth is that the Extraordinary Documents Remain Under Seal and No Partial Rel
ustralian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Epstein VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 11 EFTA00805468 LINK & ROCKENBACH, PA 1555 Palm Bea
hat's not the issue. You've done your job." (App. D-2, 59:24.) Even though this Court's stay order did not occur for an entire 24 hours after Judge Hafele's oral ruling on March 8, 2018, Epstein and his counsel took into account that the attendance by the trial judge and counsel at the Palm Beach Count
Farmer Jaffe asked that Epstein bear the costs of copying and organizing the documents but also expressed concern about Epstein and his counsel at Fowler White possibly misappropriating them, Farmer Jaffe recounted. The bankruptcy court granted the copying request with strict instructions that Fowler White
stein never even knew Fowler White had the disc until we found it." Counsel for three victims — identified as L.M., E.W. and Jane Doe — asked Judge Hafele to order Fowler White to explain its handling of the confidential documents, but he said he lacked the authority to do so since the firm had withdr
d the materials from Fowler White's files. According to the motion, during a March 8 hearing on the privileged communications, State Circuit Judge Donald W. Hafele said, "The critical question, though, is why did Fowler White have these documents, why were they continued to be held, and was it in violation eith
etting out in two affidavits (1) the chain of custody which irrefutably establish that Link & Rockenbach, PA properly obtained the "materials" from Fowler White, Epstein's prior counsel (App. C) and (2) an opinion by ethics expert, Tim Chinaris, who had authored thousands of ethics opinions for over a decad
he emergency stay of proceedings, it was Epstein's counsel who worked with opposing counsel over the weekend and appeared at 8:30 a.m. before Judge Hafele in order to enter an Agreed Order nunc pro tunc so the clerk could seal the records temporarily. (App. E.) To be clear, Epstein wants a full in ca
assell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. Dixie Highway, Room 10.1216 West Palm Beach, FL 33401 Co-Counsel for Intervenors E.W., L.M. and Jane Doe 12
pecial master to review 8 thousands of documents several days before the 9 commencement of trial for the first time, despite 10 recalcitrance from Fowler White, their somebody 11 reviewing their files apparently for the first time 12 mere weeks before the case is going to court, those 13 types of things
in, I remain concerned about waiver or perhaps the door has been opened for us to file a new petition for writ of CERT - short and sweet — requiring Hafele to do his job on remand - even if the exhibits listing was late. He used the late disclosed as a reason for not reviewing them in Camera. He verball
very, to Assess Sanctions and Costs, and for Other Appropriate Relief [DE 6353]. INTRODUCTION In their motion, the Victims sought sanctions against Fowler White and Epstein for illegally retaining copies of materials forbidden to be retained or copied by this Court's November 2010 order — including a disk o
ADMITTED THAT HE POSSESSED DOCUMENTS FROM THE DISK IN QUESTION Epstein has previously admitted in the related state court proceedings before Judge Hafele that he possessed documents from the disk in question. Now, before this Court, he appears to take a different position. For example, Epstein states
s produced for attorneys' eyes only, and then privileged documents that were not produced. But documents were delivered to Mr. Epstein's counsel, Fowler White, during that period of time. And -- THE COURT: You're talking about irrespective of what was on the disk? MR. SCAROLA: Well, when you say "irresp
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
Entities connected to both Fowler White and Donald W. Hafele

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
George W. Bush
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Donald Trump
PERSONMaria Farmer
PERSONJane Doe
PERSONPalm Beach County Courthouse
LOCATION
Jay Howell
PERSON
Scott J. Link
PERSON
Paul Cassell
PERSONNichole J. Segal
PERSONDarren Indyke
PERSONKara Berard Rockenbach
PERSONE.W.
PERSONthe Southern District
LOCATION
Fowler
PERSONMarc S. Nurik
PERSON