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17 18 19 20 21 22 23 24 25 Page 3 THE COURT: Rothstein Rosenfeldt & Adler. MR. McLACHLAN: Good morning, your Honor. Niall McLachlan from Carlton Fields on behalf of Fowler White Barnett. MR. PUGATCH: Good morning, your Honor. Chad Pugatch, P-u-g-a-t-c-h, on behalf of Jeffrey Epstein. Co-counsel,
have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,
on Fields Jorden Burt, P.A. Miami Tower 100 S.E. Second Street, Suite 4200 Miami, FL 33131-2113 November 29, 2018 Via E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit C
proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d
& Rockenbach PA and Chad P. Pugatch of Rice Pugatch Robinson Storfer & Cohen PLLC. Fowler White Burnett PA is represented by Niall T. MacLachlan of Carlton Fields. 2 of) 4/20/2018. II:48 PM EFTA00793955 Sanctions Bid Advances Against Fla. Firm. Billionaire - Law360 Imps://vAvw.law360.com/anicles/I035864/p
granted motions from former Farmer Jaffe partner Bradley J. Edwards, who represented nine of Epstein's victims, and three of those victims to join Farmer Jaffe's sanctions bid. He also ordered them to file a summary of their alleged damages with the court. The judge also decided during the hearing to order E
Entities connected to both Carlton Fields and Farmer Jaffe's

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJack Scarola
PERSONFowler White's
ORGANIZATION
George W. Bush
PERSON
Fowler
PERSONBates
PERSON
Michael Cohen
PERSON
Paul Cassell
PERSONJane Doe
PERSONthe Southern District
LOCATION
Condoleezza Rice
PERSON
Scott J. Link
PERSONDonald W. Hafele
PERSONE.W.
PERSON
Scott Link
PERSONDavid P. Vitale
PERSON
Virginia Giuffre
PERSON