Epstein Secrets

tes, digital cameras, and memory cards. 2. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units ("CPUs"), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives,

. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates

t currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central pr

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

rict of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 VIA FACSIMILE Robert I. Targ, Esq. Din Reus Rolff & Targ LLP 100 S.E. Second Street, Suite 2600 Miami, FL 33131 Re: Subpoena to Paul Lavery June 6, 2007 Dear Mr. Targ: Thank you for your letter of June 4, 2007. Following receip

nymously, having previously moved to intervene in this action and having filed a motion for an order to show cause [DE 6345], now file this reply to Jeffrey Epstein's Response in Opposition to ■., ■., and Jane Doe's Joinder in Motion for Order to Show Cause and Motion for Discovery, to Assess Sanctions and Costs,

anctions and Costs, and for Other Appropriate Relief [DE 6353]. INTRODUCTION In their motion, the Victims sought sanctions against Fowler White and Epstein for illegally retaining copies of materials forbidden to be retained or copied by this Court's November 2010 order — including a disk of thousands

r to show cause [DE 6345], now file this reply to Jeffrey Epstein's Response in Opposition to ■., ■., and

e won't use them. MR. SCAROLA: Does that include Mr. Epstein? THE COURT: Does what include Mr. Epstein? MR.

Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. 13 EFTA00795957 Case 09-34791-RBR Doc 6357 Filed 04/12/18 Page 14 of 14

effrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009CA040800XXXXMBAG Dear Niall and Joe: This letter is Jeffrey Epstein's demand to Fowler White, pursuant to section 627.4137, Florida Statutes, for the following: A statement under oath of a corporate officer for Fowler

ard West Palm Beach, FL 33401-6350 RE: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h J

e Boulevard West Palm Beach, FL 33401-6350 RE: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards

I M R CIVIL TRIAL 8, APPELLATE LAW LINK& ROCKENBACH, PA Via Email Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 Miami, FL 33131 1555 Palm Beach Lakes Blvd Suite 301 West Palm Beach. FL 33401 TEL (561) 727.3600 I FAX (561) 727-3601 April 3, 2018

issing Edwards Fistos & Lehrman, Bradley J. Edwards and Intervenors L.M., E.W. and Jane Doe, voluntarily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action which have or could have been asserted in this action and all claims for all forms of damages, including co

compensatory damages, sanctions, punitive damages, prejudgment interest, costs and attorneys' fees. Farmer Jaffe, Edwards, L.M., E.W., Jane Doe and Epstein will each bear their own attorneys' fees and costs. Dated: , 2018. Respectfully submitted, EDWARDS POTTINGER LLC Bradley J. Edwards FLBN Britt

arily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action

Jane Doe Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Isaac M. Marcushamer Carlton Fields Jorden Burt, P.A. Berger Singerman LLP 100 S.E. Second Street, Suite 4200 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. Counsel for Liquidating Trus

of the requested relief they are seeking in this case. The Victims now file that list. The victims seek the following relief: I. Fowler White and Epstein (including all of Epstein's past and present legal counsel) will provide to the Victims' counsel, within seven days of the Court's order, a listing

buted, as well as a certification that they have asked for return of the subject materials. 2. A letter written and signed by both Fowler White and Jeffrey Epstein, and sent to all persons known or suspected to have reviewed or obtained any copies of the documents at issue, to the following effect: "To Whom It

etter written and signed by both Fowler White and Jeffrey Epstein, and sent to all persons known or suspec

Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 100 S.E. Second Street, Suite 4200 Miami, FL 33131 [email protected] Counsel for Fowler White Burnett, P.A. EFTA00808136 Case 09-34791-R BR Doc 6384 Filed 05/