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a clear review of documents that Fowler White knew it was not permitted to have in its possession. Perhaps more compelling, Mr. Hurley's review of Fowler White's internal records indicated that in 2014, Fowler White created an inventory of the items in its possession relating to Jeffrey Epstein when Fowler W
s no longer voluntarily willing to pay for the service. While Farmer Jaffe's motion was pending, Special Master Carney contacted Farmer Jaffe about Fowler White's offer to copy and Bates stamp the documents in-house to save Epstein costs. Special Master Camey recommended that Fowler White's offer be accepted
s numbering of this large volume of documents be incurred by Jeffrey Epstein, as he was no longer voluntarily willing to pay for the service. While Farmer Jaffe's motion was pending, Special Master Carney contacted Farmer Jaffe about Fowler White's offer to copy and Bates stamp the documents in-house to save
FTA00787726 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 Pagell the single CD that was supposedly in Fowler White's files, that's correct. There was originally, my understanding is, two CDs that were delivered to Fowler White for printing. Those documents were t
rs, which ended up with the order that we're talking about today. Another point of clarification, Mr. Scarola says that the order was entered over Farmer Jaffe's objection. He may have had some -- the law firm may have had some concerns, but it's very clear it's an agreed order. I don't know that that makes
name is M-c-L-a-c-h-1-a-n. I omitted that earlier. Judge, we have several matters on the calendar this morning. We have the continued hearing on Fowler White's motion for protective order, that's Docket Entry 6421. You may recall we had a hearing earlier, and the Court indicated that it would give, it wou
have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,
writing on behalf of my client, Jeffrey Epstein, in response to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's representation of him in the above-referenced matters during the period of June 2010 through May 2012. We are hopeful to put this matter to rest on
proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d
. Movants request sanctions against Fowler White, a law firm which withdrew from representing any party in this case nearly six years ago. DE 3034. Fowler White's investigation has not revealed how the offending CF ended up in its files since it sent the disk back to Special Master Carney after printing the do
ONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fowler White Burnett, P.A. ("Fowler White"), by and through undersigned counsel, hereby responds to Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to
bid. He also ordered them to file a summary of their alleged damages with the court. The judge also decided during the hearing to order Epstein and Fowler White's corporate representative to sit for depositions on the limited scope of how Epstein and his current counsel came to possess a compact disc allegedl
granted motions from former Farmer Jaffe partner Bradley J. Edwards, who represented nine of Epstein's victims, and three of those victims to join Farmer Jaffe's sanctions bid. He also ordered them to file a summary of their alleged damages with the court. The judge also decided during the hearing to order E
ein and D. Indyke re same; work on objection to duces tecum; work on Response to S. Rothstein's Motion to Dismiss; communications with J. lanno re Fowler White's insurance information 06/19/18 RJG Review Notice and Re-Notice of taking Video 1.90 750.50 Deposition Duces Tecum of J. Epstein, Bankruptcy Cou
onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried in order to interview jurors; research Farmer
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
there had been a waiver of any privilege with regard to documents contained on the disc that permitted you to file documents that were included on Farmer Jaffe's privilege log. Ianno (Fowler White's counsel): And I want to add my objection that that has nothing whatsoever to do with the motion, the order or
ein and D. Indyke re same; work on objection to duces tecum; work on Response to S. Rothstein's Motion to Dismiss; communications with J. lanno re Fowler White's insurance information 06/19/18 RJG Review Notice and Re-Notice of taking Video 1.90 750.50 Deposition Duces Tecum of J. Epstein, Bankruptcy Cou
onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried In order to interview jurors; research Farmer
Entities connected to both Fowler White's and Farmer Jaffe's

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJack Scarola
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Fowler
PERSONJane Doe
PERSON
George W. Bush
PERSON
Scott J. Link
PERSONBates
PERSON
Fowler White Burnett
ORGANIZATIONE.W.
PERSONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONDonald W. Hafele
PERSON
Weissing
PERSONCarney
PERSONthe Southern District
LOCATION