Epstein Secrets

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

October 19th, 2018 10:05 a.m. - 2:29 p.m. 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Servi

Order did not "sit in a box" for the past eight (8) years. This fact, however, was only uncovered at the October 19, 2018 deposition duces tecum of Fowler White's corporate representative, which was conducted after Epstein's deposition on October 13, 2018. Thus, the Court should not excuse Epstein from attend

r 13th, 2018 9:07 a.m. - 11:00 a.m. 1555 Palm Beach Lakes Boulevard, #930 West Palm Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 EXHIBIT Palm Beach Report

received select documents from the disc in February 2018. The select documents were provided to Epstein after Link & Rockenbach located the disc in Fowler White's boxes in February 2018. Because there are no material facts in dispute, live testimony will have no impact on this Court's determination of whether

1555 Palm West Palm October 13th, 2018 - 11:00 a.m. Beach Lakes Boulevard, #930 Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. 561-471-

of your declaration, Exhibit Number 1, states, "In February 2018, Scott J. Link of Link & Rockenbach, PA, informed me that he had located a disc in Fowler White's files labeled," quote, Epstein Bate Stamp, unquote. Did I read that accurately? A: Correct. Q: That was a communication from Mr. Link, your lawyer

1555 Palm West Palm October 13th, 2018 - 11:00 a.m. Beach Lakes Boulevard, #930 Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. 561-471

Judge Ray's order. BY MR. CASSELL: Q What does paragraph four mean, Mr. Epstein? A It says Scott Link informed me that he had located a disc in Fowler White's files labeled "Epstein Bate Stamp" -- quote, Epstein Bate Stamp. Q Please tell me all that he informed you of. Palm Beach Reporting Service, Inc.

ge 102 of 165 2 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 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 APPEARANCES: For Jeffrey