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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
to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac
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
to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac
bate stamped pages of documents. Rather, Special Master Carney wanted a searchable disc. It is still a mystery how and when the disc came back into Fowler White's possession after it was sent to Special Master Carney and no evidence has been presented to resolve that question definitively. 5Excerpts of the Ma
dwards' failure to comply with the Court's Order. Because Edwards blatantly disregarded the Court's Order, as well as the requirements of Florida's Rules of Civil Procedure and the TIG case, the February 23, 2011 privilege log remains for any number of wholly deficient and worse - misleading. The privilege log misstate
Entities connected to both Fowler White's and Rules of Civil Procedure

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