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their very own creation by either attorney-client or work product. If the disc somehow improperly came into the possession of Fowler White and Mr. Ackerman (of which Mr. Cassell has not even the slightest of proof), then the most one could say is that for eight years Fowler White and Mr. Ackerman held
y, no competent lawyer could review the materials that are now sealed and not insist on an in camera review of their contents. Fowler White and Mr. Ackerman's failure to do so makes it much less likely that they knew what was on the disc. There can be no urgency created by the revelation of eight-year-ol
ay with Request for Expedited Consideration" and as grounds states: Introduction No legal standing or basis exists for non-parties, L.M., E.W., and Jane Doe, to "join" any appellate motion or action by Edwards.' The unnecessary intervention appearance below by E.W., L.M. and Jane Doe, while never reduce
I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR
mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1
RE II Deoksbor 5th and nide it clear to all parties that 10 12 exhibits that. here net disclosed by the end of II For Non-Parties L.M., E.M. 4 Jana Doe 22 1a Deoabor -- and I think it nay have been the 14 De her 22 dace -- I'm not sure about that exact 13 la date -- but exhibits that were no
I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR
mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1
question in front of you sight now is • very brief, representing three victims; LH, EM and • what to do about this. Well, we knee one thing. • Jane Doe. /Vat ono housekeeping natter. s lie know there's been absolutely no waiver of 10 No have riled a notion to intervene, which is 10 attorney/cl
fashion so that, 25 NR. LINK: He la, yea. And we reached out ' 34 36 , motor one, first and foremen[ once all the cards I Joe Ackerman. Kr. Ackerman. Sorry. We reached . are on the table, the law favors settlement, and it 2 out to Mr. Ackerman. may come tO fruition, and has more often than no
er white. They have no memory of it. *o we, LIA, Mr. $•Carole -- that the Court had a specific interest in and has 23 THE COURT: Excuse 04. LA MX. Ackerman atilt I always taken the position that all cards are going 24 actively practicing? to bo on the table in a timely fashion so that, 25 NR. LINK
oulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe HATCH, JAMES 4 DODGE, P.C. 10 Nest Broadway, Suite 400 Salt Lake City, UT 84101 By PAUL G. CASSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBUR
ll of when were involved at some point 21 In time in the representation of Jeffrey Epstein, 32 Correct? 33 A Yea. 24 Q I think I missed Mr. Ackerman on that list. 23 Mr. Ackerman as well. 136 I BY NE. SCAROLA: 2 Q Lot me restate the question. 3 what extent, if any, would it be necessary
9 accident 94:23 95:17 account 29:15 accountable 107:14 accounts 29:1,2,5 accurate 114:13 accused 46:23 151:9 accusing 50:11 achieved 122:3 Ackerman 90:18 134:24.25 135:1.2 acknowledge 56:24 acknowledged 135:6 acquainted 15:14 acquired 19:13 act 53:24 acted 136:5 acting 134:3 action 8:2
riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc
ckell AV Ste 1400 Miami FL 33131 Scarola, John 2139 Palm Beach Lakes BL West Palm Beach FL 33409 Back to Too Additional Counsel EFTA00227002 Ackerman. Joseph L 515 N Flagler Drive 20th Floor Northbridge CE West Palm Beach FL 33401 Adler, Russell S 401 E Las Olas Blvd Suite 1650 Las Olas City F
82 Mcmp Motion to Compel And For Sanctions 05/06/2009 83 Notd Notice of Taking Deposition LM 05/06/2009 84 Notd Notice of Taking Deposition Jane Doe 05/06/2009 85 Mot Motion For Protective Order 05/06/2009 86 Mot Motion For Protective Order 05/07/2009 87 Mot Motion Forprotective Order
Begin forwarded message: From: Date: February 25, 2011 3:20:34 PM EST To: Subject: Urgent media query for your client Mr. Jeffrey Epstein Dear Mr. Ackerman: We will be most grateful for responses from Mr. Jeffrey Epstein on the following; I. That is Jane Doe 102 2. That Mr. Epstein regularly paid he
your client Mr. Jeffrey Epstein Dear Mr. Ackerman: We will be most grateful for responses from Mr. Jeffrey Epstein on the following; I. That is Jane Doe 102 2. That Mr. Epstein regularly paid her a minimum of $200 for sexual favors from the age of 15 3. That Mr. Epstein funded and organised a trip
," court papers say. "During all of these depositions, Epstein refused to answer any substantive questions about his sexual abuse of minor girls." Ackerman said the Rothstein lawsuit is a different situation than Epstein taking the Fifth in depositions regarding the victims, because the allegations aga
timidate him so as to abandon the justified prosecution of his claims against Mr. Epstein," Scarola said. Edwards secured deals for victims N, and Jane Doe, who were among nearly two dozen young women who received confidential settlements from Epstein. Edwards filed a new lawsuit last month against Eps
y Jeffrey Epstein re 214 Defendant's MOTION for Protective Order and Objection to Disclosure of Certain Documents with Integrated Memorandum of Law (Ackerman, Joseph) (Entered: 09/02/2010) Copyright 2011 LexisNexis CourtLink, Inc. All rights reserved. "" THIS DATA IS FOR INFORMATIONAL PURPOSES ONLY •••
by Jeffrey Epstein. (Pike. Michael) (Entered: 07/02/2010) 07/05/2010 199 Defendant's MOTION in Limine to Exclude Certain Testimony and Opinions of Jane Doe's Expert Witness by Jeffrey Epstein. (Pike, Michael) (Entered: 07/05/2010) 07/05/2010 200 RESPONSE in Opposition re 190 Plaintiff's MOTION for Cont
Entities connected to both Ackerman and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Salt Lake City
LOCATIONScott Rothstein
PERSON
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION