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ler White had in its files and turned over in February 2018 to Epstein's current trial counsel, Link & Rockenbach. The Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention.
endant Jeffrey Epstein ("Epstein") moves to unseal the disc labeled "Epstein Bate Stamp" and the 47 documents identified on Epstein's March 5, 2018, Clerk's Trial Exhibit List for the limited purpose of the Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRO
finding whether Fowler White or Epstein retained any copies of the documents contained on the disc or any images of the documents in the memories of Fowler White's copiers. Following a preliminary hearing held on April 13, 2018, in the Bankruptcy Court, Judge Ray ordered discovery that is focused on the allega
nd March 2, 2018. Epstein then individually identified each of those exhibits according to the Clerk's pre-marking guidelines on his March 5, 2018, Clerk's Trial Exhibit List. 6 EFTA00808677 THE COURT: Well, the only thing that obviously has to be taken into consideration is the appellate rights of
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
nd March 2, 2018. Epstein then individually identified each of those exhibits according to the Clerk's pre-marking guidelines on his March 5, 2018, Clerk's Trial Exhibit List. 6 EFTA00808663 (3/8/18 Aft. Tr. 54:9-20) (emphasis added). This Court's rulings were focused on not allowing Epstein to use
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
for default, etc.; work on documents re same; multiple communications with J. Scarola re production issues; follow up with client re same; work on Clerk's Trial Exhibit List 03/19/18 KBR Finalize Reply in support of Petition for Writ of Mandamus 03/23/18 TMB [No Charge] Work on exhibits and finaliz
tion for Writ of M I ;ion for Writ of Certiorari; revii ' 17 monse to our Petition for Man to Lift Stay; follow up with D. Indy Jo reviewing Fowler White's recur .;duction; follow up with J. Hurl( EFTA00799125 Client Ref: 0002 - 000 Invoice # 396 Date Servi 03/12/18 KBR Prep, •ten I hearing
ssing Scope of Admissible Evidence; work on hearing needs; follow up on V. Roberts' audio tape; prepare Notice of Cancellation of Hearing; work on Clerk's Trial Exhibit List to identify each item individually 03/02/18 SJL Continue working on Notice of Filing Appendix in 12.80 9,600.00 Support of R
Entities connected to both Fowler White's and Clerk's

Bradley Edwards
PERSON
Jeffrey Epstein
PERSONScott Rothstein
PERSONJack Scarola
PERSONMaria Farmer
PERSONJack Goldberger
PERSON
Fowler
PERSON
Paul Cassell
PERSONJane Doe
PERSON
Scott J. Link
PERSON
George W. Bush
PERSONPalm Beach Lakes Boulevard
LOCATIONBates
PERSONE.W.
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONKara Berard Rockenbach
PERSONDonald W. Hafele
PERSON
Jay Howell
PERSONDavid P. Vitale
PERSONDarren Indyke
PERSON