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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
orneys at the law firm of Fowler White Burnett, P.A. ("Fowler White")—would make a copy of the materials and return them to Fanner Jaffe. Because of Fanner Jaffe's obvious concern that 1 EFTA00799314 Case 09-34791-RBR Doc 6323 Filed 03/19/18 Page 2 of 23 Epstein or his legal counsel might misappropriate
of them are 22 privileged. They submitted a privilege log, Mr. Scarola 23 said it was for this Court. It wasn't. The privilege log 24 is in Judge Hafele's court, in the 15th Judicial Circuit 25 in Palm Beach County. Page 18 1 MR. LINK: Judge, if I can just respond 2 briefly on behalf of Mr. Epst
ended up with the order that we're talking 14 about today. IS Another point of clarification, Mr. Scarola 16 says that the order was entered over Fanner Jaffe's 17 objection. He may have had some — the law firm may have 18 had some concerns, but it's very clear it's an agreed 19 order. I don't know that th
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
pursue production of them further solidifies Mr. Epstein's malpractice claims. While approximately 1,600 documents from the disc were identified on Fanner Jaffe's privilege log, because Fanner Jaffe (1) produced some of the documents on its log, (2) expressly agreed to produce gtl work-product documents to Fo
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
issues. DE 6353 at 5-6. This argument does not address the more basic attorney-client privileges, which have never been waived in any way. But, as Fanner Jaffe's briefing clearly explains, there has never been any waiver — either of attorney-client privilege or work-product protection — over the "key emails"
Entities connected to both Donald W. Hafele and Fanner Jaffe's

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
George W. Bush
PERSONScott Rothstein
PERSONJack Scarola
PERSONMaria Farmer
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Scott J. Link
PERSONE.W.
PERSON
Fowler
PERSONFowler White's
ORGANIZATIONthe Southern District
LOCATIONPalm Beach Lakes Boulevard
LOCATION
Weissing
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONDavid P. Vitale
PERSONBates
PERSON
Fowler White Burnett
ORGANIZATION