Epstein Secrets

f from Stay 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, whil

f custody and ethical handling of the documents-turned-exhibits. (App. B and App. C.) "I'm not finding fault with anything you [Scott Link] or Miss Rockenbach or Miss Campbell did. That's not the issue. You've done your job." (App. D-2, 59:24.) Even though this Court's stay order did not occur for an enti

y" identified by Epstein's current counsel. Attempting to discern the origin of the emails (clearly legally and properly obtained by Scott Link and Kara Rockenbach), the trial judge ultimately concluded that he would deal after trial, if at all, with the how predecessor counsel, Fowler White, obtained the docu

to have dealt with this issue head on because of the apparent implications of same." Hearing Trans. at 60:20-61:14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to. Judge Hafele indicat

client. And I can say legal counsel, Mr. Goldberger. So that's it." Hearing Trans. 64:14-19. 30. During the hearing, counsel for Epstein (Link and Rockenbach) also revealed that Fowler White was disclaiming any memory of the circumstances surrounding the creation and retention of the disc: "We have reach

cause, for representing then-minor girls sexually abused by Epstein, including L.M. 21. On March 2, 2018, Epstein, through counsel Scott Link and Kara Rockenbach, Epstein filed Plaintiff/Counter-Defendant Jeffrey Epstein's Notice of Filing of Redacted Appendix in Support of Response in Opposition to Defendan

-RBR Doc 6488 Filed 10/22/18 Page 103 of 165 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH 332 S. University Street Salt Lake City, UT 84112 By PAUL G. CASSELL, ESQUIR

7 18 19 20 21 22 23 24 25 come from 10 years and other sources. If you're going to ask him if he has any documents as a result of Link .4 Rockenbach's CD -- the CD from February of 2018, ask him that. But don't be generic and ask him if he just has documents whatsoever without any reference to

neys please announce their appearances for the record? MR. SCAROLA: Jack Scarola appearing on behalf of Bradley Edwards. MR. LINK: Scott Link and Kara Rockenbach on behalf of Jeffrey Epstein. MR. IANNO: Joseph Ianno, Carlton Fields on behalf of Fowler White. MR. GOLDBERGER: And Jack Goldberger on behalf o

ons, and in support thereof, states: INTRODUCTION Counter-Plaintiff Bradley J. Edwards ("Edwards"), along with Fanner Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a November 2010 Agreed Order' h

use proceedings and the upcoming depositions. BACKGROUND During the March 8, 2018, hearing, the Court instructed Epstein to file under seal Link & Rockenbach's copy of the disc and exhibits identified on Epstein's March 5, 2018, Clerk's Trial Exhibit List which Edwards claimed were privileged. The exhibit

ceedings and depositions, and in support thereof, states: INTRODUCTION Defendant, Bradley J. Edwards, along with Farmer Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a November 2010 Agreed Order h

use proceedings and the upcoming depositions. BACKGROUND During the March 8, 2018, hearing, the Court instructed Epstein to file under seal Link & Rockenbach's copy of the disc it located in Fowler White's files and exhibits identified on Epstein's Trial Exhibit List which Edwards claimed were privileged.

tions in connection with 2 EFTA00793292 these materials so that I can be certain that you have fully protected the rights of third parties L.M., E.W., and Jane Doe. Respectfully submitted, Paul G. Cassell, Esq. for L.M., E.W., and Jane Doe 3 EFTA00793293

L 33401 Via email: [email protected] [email protected] Re: Your Possession of Confidential and Privileged Materials Dear Mr. Link and Ms. Rockenbach: I write on behalf of three of my clients, whom I will refer to as L.M., E.W., and Jane Doe. I believe you are familiar with their identities as ch

or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, P.A. Isaac M. Marcushamer Coun

ng line of questions about his firm's review of the disc after its discovery: Q. How did she [Paralegal Tina Campbell] review the disc contents? Rockenbach (counsel for Mr. Link): I am going to object on the basis of, not only work product protection, but that this exceeds the scope of Judge Ray's orde

ckenbach PA told Law360, "Mr. Epstein never even knew Fowler White had the disc until we found it." Counsel for three victims — identified as L.M., E.W. and Jane Doe — asked Judge Hafele to order Fowler White to explain its handling of the confidential documents, but he said he lacked the authority

s & Lehrman PL is represented by Bradley J. Edwards and Brittany N. Henderson of Edwards Pottinger LLC. Epstein is represented by Scott J. Link and Kara Rockenbach of Link & Rockenback PA and Jack A. Goldberger of Atterbury Goldberger & Weiss PA. Edwards is represented by Jack Scarola and David P. Vitale of Se

ls are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and d

ou've done your job." (March 8, 2018, Aft. Tr. 59:1-4.)5 • "So I again want to make clear that I'm finding absolutely no fault with Mr. Link, Miss Rockenbach, Miss Campbell or anyone else from the Link and Rockenbach firm in terms of what they did, albeit in the manner in which they had to do it and the

2874 65 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to interrogatories in the state court matters, E.W. and L.M., and listed additional high-profile witnesses that would allegedly be called at trial, including, but not limited to:" And then various

have violated my order. The replies are being ignored. I do not expect that to be repeated, absent sanctions. Is that understood? Both sides? Ms. Rockenbach? DRAFT ONLY !!!! NOT PROOFREAD EFTA00792813 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MS. ROCKEN