Epstein Secrets

federal civil contempt relating to the alleged violations of the November 2010 Agreed Order. Specifically, Edwards may take the depositions of (1) Fowler White's representative about the chain of custody of the discovery documents; (2) Epstein about his knowledge or possession of the disc or documents pre-20

ng, Edwards, himself, would be in violation of the Court's ruling by his reference to the e-mails in filings in this Court, the Appellate Court and the Bankruptcy Court. In fact, Epstein has taken numerous affirmative steps to ensure compliance with the Court's directives at the March 8, 2018 hearing. The disc is se

in any copies of the documents contained on the discs provided to it, nor shall any images or copies of said documents be retained in the memory of Fowler White's copiers. Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherwise, the

er White's possession and retention of the CD at issue is currently the subject of a Motion for Issuance of an Order to Show Cause that was filed in the Bankruptcy Court on March 19, 2018. The Bankruptcy Court has scheduled a hearing on that motion for April 13, 2018. 4 EFTA00811314 Edwards adv. Epstein Case No.

20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is permitted to depose Epstein in Palm Beach County concerning Epstein's knowledge of Fowler White's retention of the disc at issue. This line of inquiry includes whether Epstein had possession of the disc at any point prior to February 2018, when

f Epstein's deposition. I The Court recognized that the privileged materials at issue were likely subject to an order from Judge Raymound B. Ray of the Bankruptcy Court for the Southern District of Florida. 3/8/18 Afternoon Session Tr. at 52:6-19; 54:9-20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is

ns against Epstein, he will seek recovery from Fowler White because Fowler White retained a copy of the disc without his knowledge. Second, but for Fowler White's actions in retaining the disc, the show cause proceedings would never have been brought against Epstein. Epstein has expended substantial attorneys'

od of June 2010 through May 2012. Potential Malpractice and Breach of Fiduciary Duty Claims Against Fowler White First, in the very unlikely event the Bankruptcy Court awards sanctions against Epstein, he will seek recovery from Fowler White because Fowler White retained a copy of the disc without his knowledge. S

ing on case management; communications with D. Vitale re proposed sealing order, work on Motion to Maintain Case Style; follow up with J. lanno re Fowler White's Insurance policy 04/04/18 KBR Prepare e-mail to D. Vitale se style and dismissal with prejudice of in 2010; analyze case law re case style cha

Writ of Certiorari; work on Response to B. Edwards' Motion to Permit to Take the Limited Deposition of J. Epstein; review Farmer Jaffe's Motion in the Bankruptcy Court and the Bankruptcy Court hearing transcript for cites to reference in same Hours May 7, 2018 Page 10 Amount 6.20 4,650.00 0.10 0.00 3.90