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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
taining information derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack?
er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0
AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through counsel, hereby moves this honorable Court for an Order to Show Cause Wh
e time you were employed by RRA (or that is being claimed by the Trustee). 20. In the attached transcript dated July 31, 2009, you stated to Judge Hafele with regard to the E.W. and L.M. cases the following: 5 EFTA00724400 "What the evidence is really going to show is that Mr. Epstein — at least
n Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659.8300 Fax (561)-835-8691 Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Fanner, Jaffe, WelssIng, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (964) 524-
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
Lachlan Joseph Ianno, Jr. November 29, 2018 Page 2 will provide a set of copied, stamped documents to the Special Master and an identical set to Fanner, who will use same to create its privilege log. ... Fowler White will not retain any copies of the documents contained on the discs provided to it,
Beach, FL 33401 1 EFTA00798167 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401 and to all counsel on the attached service list, by email, on March 12, 2018. Jack
ilroad Avenue West Palm Beach. FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 11 A31 EFTA00798197 Bradley J. Edwards Fanner, Jaffee, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale FL 33401 Co-Counsel for Defendant/Counter-Plain
Entities connected to both Donald W. Hafele and Fanner

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONMaria Farmer
PERSON
Donald Trump
PERSONJane Doe
PERSONJaffe
PERSON
Weissing
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONRobert D. Critton
PERSONthe Southern District
LOCATIONFISTOS & LEHRMAN
ORGANIZATION
Kenneth Marra
PERSONPalm Beach County Courthouse
LOCATION
Prince Andrew
PERSON
Scarlett Johansson
PERSON