Epstein Secrets

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.

Doc 6357 Filed 04/12/18 Page 14 of 14 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Avenue, Suite 1900 Miami FL 33131 Counsel for Litigating Trustee 14 EFTA00795958

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

of 6 Isaac M. Marcushamer Berger Singerman LLPO 1450 Brickell Avenue, Suite 1900 Miami, FL 33131 [email protected] Counsel for Litigating Trustee EFTA00808137

ne in this action, and having participated in the Court's hearings on these matters, and pursuant to this Court's order of August 16, 2018, denying Epstein's motion to strike the victims' previously filed list of requested relief (DE 6427), now file this summary of their damages. The factual background

hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlton Field

hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlt

s Jorden Burt P.A. Miami FL 33131 Counsel for Fowler White Burnett, P.A. Isaac M. Marcushamer Ber er Sin erman LLPO Miami. FL 33131 Counsel for Litigating Trustee 5 EFTA00809903