Epstein Secrets

Epstein v. Scott Rothstein and Bradley J. Edwards, 15th Judicial Circuit Case No. 50-2009-CA- 040800XXXXMBAG) and the show cause proceedings (In re Rothstein Rosenfeldt Adler, P.A., U.S. Bankruptcy Court, Southern District of Florida, Case No. 09-34791-RBR) but will also address Epstein's potential claims against Fowler

hat Edwards claims are privileged and are currently under seal may be unsealed at the mediation and shown by Epstein's attorneys to the mediator and Fowler White's attorneys. Edwards' counsel shall bring Edwards' copy of the 47 e-mails to the mediation for this limited purpose. 8. The use of the 47 e-mails d

Jaffe who have the full authority to settle without further consultation shall appear at the mediation in person. Furthermore, a representative of Fowler White's insurance carrier who has full authority to settle in an amount up to its policy limits without further consultation shall appear at the mediation i

o you know how many discs there were included within those 30-plus boxes that contained electronically-stored information that originated with the Rothstein Rosenfeldt Adler or Farmer Jaffe law firms? MR. IANNO: Object to the form. THE WITNESS: As I sit here today, I don't know if there were any discs in that file th

t Fowler White was unaware, as of the time that it came into possession of the discs delivered in response to the subpoena that had been issued at Fowler White's request, that Fowler White had an obligation to protect against any access to privileged or potentially privileged information on that disc; is th

eipt on the 8th. Q To whom were they directed in the Miami office? A I believe they were sent to Ms. Sanchez, but I'm not positive. Q What is Fowler White's understanding as to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803650 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1

in the possession of Epstein were originally formatted in the way described above by the law firm of Berger Singerman, as counsel for the Trustee of Rothstein Rosenfeldt Adler ("RRA") in the Federal Bankruptcy proceeding litigated before United States Bankruptcy Court Judge Raymond B. Ray in case 09-34791. 4. The subjec

in 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 conies of the subject documents on its computer or otherwise, the

Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009-CA-040800XXXXMBAG In re Rothstein Rosenfeldt Adler, P.A. U.S. Bankruptcy Court, Southern District of Florida, Case No. 09-34791-RBR Dear Niall and Joe: I am writing on behalf of my client, Jeffrey

writing on behalf of my client, Jeffrey Epstein, in response to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's representation of him in the above-referenced matters during the period of June 2010 through May 2012. We are hopeful to put this matter to rest on

(Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards, 4 Judicial Circuit Case No. 50-2009-CA- 040800X)OOCMBAG) and the show ceedings (In re Rothstein Rosenfeldt Adler, P.A., U.S. Bankruptcy Court, Southpth. t of Florida, Case No. 09-34791-RBR) but will also address Epstein's potential clai ainst Fowler White.

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