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at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Farmer Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and which contains all electronically stored information ("ESI") and other documents in the Trustee's possession, respecting the
ounsel. Fanner Jaffe shall furnish copies of the segregated documents to which it asserts a privilege both to the Special Master and the Trustee at Farmer Jaffe's cost. d. To the extent that documents on the CD are duplicated and not subject to an assertion of privilege, they shall be forthwith provided to c
ct privileged 1 EFTA00793668 information. By Order dated August 13, 2010 [DE 888] this Court ordered the documents be produced to Special Master Robert Carney for the purposes of the Special Master preparing a privilege log, and that all legal fees and costs incurred by the Special Master be paid by Epstei
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
at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Fanner Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and which contains all electronically stored information ("ESI") and other documents in the Trustee's possession, respecting the
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
and resulting dissemination of the subject privileged materials. Such inquiry should include, but not be limited to, testimony from Special Master Robert Carney, Jeffrey Epstein, Fowler White Attorney Joseph L. Ackerman, Fowler White Attorney Lilly Ann Sanchez, Jack Goldberger, Tina Campbell, Scott Link, Ka
n this case on behalf of Epstein from the Gunster law firm. 7. Epstein will pay Fanner Jaffe reasonable attorneys' fees and expenses connected with Farmer Jaffe's efforts to determine the circumstances surrounding the retention and release of the materials and to undo any damage caused to Famer Jaffe or its cl
with jurisdiction over all discovery sought from the RRA Trustee. 6. On August 13, 2010, this Court appointed former Broward County Circuit Judge Robert Carney as Special Master, who was directed to work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by J
Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffe's Privilege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to i
Entities connected to both Robert Carney and Farmer Jaffe's

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJack Scarola
PERSON
Weissing
PERSON
George W. Bush
PERSONJack Goldberger
PERSONthe Southern District
LOCATIONBates
PERSONJane Doe
PERSONFowler White's
ORGANIZATIONJaffe
PERSON
Paul Cassell
PERSON
Fowler White Burnett
ORGANIZATIONROTHSTEIN ROSENFELDT ADLER
ORGANIZATIONFanner
PERSON
Prince Charles
PERSONJoseph L. Ackerman
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION