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

e delivered to the Link firm, they were done in two stages. The first stage, the Link firm came to our office -- I believe it was Scott and mostly Tina Campbell -- to review the documents. They flagged certain documents that they wanted to have received. We provided copies of the hard documents that they

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

did not improperly obtain thee, nor were they inadvertently disclosed co us. 4 earlier attempted to exclude the surprise testimony • THE COURT: Tina Campbell is your paralegal? 5 by an unsuccessful notion in limlne. Furthermore, a MS. RCCICENBACH: 4010 obtained the three boxes, 4 prejudice in the con

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

did not improperly obtain thee, nor were they inadvertently disclosed co us. 4 earlier attempted to exclude the surprise testimony • THE COURT: Tina Campbell is your paralegal? 5 by an unsuccessful notion in limlne. Furthermore, a MS. RCCICENBACH: 4010 obtained the three boxes, 4 prejudice in the con

hat request. (D.E. 6325; D.E. 6345.) Movants allege that Fowler White EFTA00794256 and Epstein violated this Court's November 2010 Agreed Order by Fowler White's alleged retention of a copy of a disc that was provided to Epstein and his current counsel (Link & Rockenbach) in 2018. (D.E. 6326 at 6-11.) The No

25:8-26:15). Mr. Link was also asked a long 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 thi

K: And I agree with that. The, 12 Lieges or copies of said documents be retained in bankruptcy court reserved that. ghat I'm 13 the memory of Fowler White's copies. And we .4 suggesting to the Court is I don't think it's as le already went through the sanctions. ., clear as Mr. Scarola said. And

inadvertently disclo.. And it aaya, quote, 'The opposing party also a to us. i earlier attempted to exclude the surprise testimony 4 THE CURT: Tina Campbell is your paralegal' • by an unsuccessful notion in limlne. Furthernare, 5 /12. ROCWITEACH: Who obtained the three boxes. prejudice in the context