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0 and RICE PUGATCH ROBINSON STORFER & COHEN. by 10 of his obvious concern about the allegations in the II CHAD P. PUGATCH. Esquire On behalf of Jeffrey Epstein 11 motion. 12 12 MR. PUGATCH: Good afternoon, your Honor. 13 CARLTON FIELDS. BY NIALL SKLAUCHLAN. Esquire 13 Chad Pugatch, P-u-g-a-t-c-h, her
tive intervenors. For that reason I think the motion 23 should be denied as to E.W. and Jane Doe. 24 MR. PUGATCH: Your Honor, on behalf of 25 Mr. Epstein, we would join in that objection, that limited Page 6 THE CLERK: Okay. 2 ECRO: Do you want me to print you a 3 calendar that shows his name? 4
n the II CHAD P. PUGATCH. Esquire On behalf of Jeffrey Epstein 11 motion. 12 12 MR. PUGATCH: Good af
e. 24 MR. PUGATCH: Your Honor, on behalf of 25 Mr. Epstein, we would join in that objection, that limited P
ended up with the order that we're talking 14 about today. IS Another point of clarification, Mr. Scarola 16 says that the order was entered over Fanner Jaffe's 17 objection. He may have had some — the law firm may have 18 had some concerns, but it's very clear it's an agreed 19 order. I don't know that th
ad Edwards began practice in his own firm and, shortly thereafter, he filed civil lawsuits against Jeffrey Epstein on behalf of multiple victims of Jeffrey Epstein's serial molestation of dozens of young children. In 2009, Brad Edwards took a job as an attorney at Rothstein, Rosenfeldt, Adler ("RRA") and continu
RA law firm, filed a false and baseless law suit in Palm Beach Case Number 50-2009-CA-040800 against Scott Rothstein, Brad Edwards, and L.M.—one of Epstein's many child victims. In late 2009, RRA was placed into bankruptcy and a trustee, Herb Stettin, was assigned. Herb Stettin was represented by the l
ortly thereafter, he filed civil lawsuits against Jeffrey Epstein on behalf of multiple victims of Jeffrey
ess be performed by Fowler White in order to save Mr. Epstein money. As is evident by the email correspondence
TA00793669 confidentiality is breached or some residue or image of our documents remains at [Fowler White]." Special Master Carney took offense to Fanner Jaffe's insinuation that Jeffrey Epstein or any member of his legal team might look at the documents that were being printed at Fowler White or might retai
lvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards
nse to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's rep
i, FL 33131-2113 November 29, 2018 Via E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009-CA-040800XXXXMBAG In re Rothstein Rosenfeldt Adler, P.A. U.S. Ban
9-34791-RBR Dear Niall and Joe: I am 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.
pursue production of them further solidifies Mr. Epstein's malpractice claims. While approximately 1,600 documents from the disc were identified on Fanner Jaffe's privilege log, because Fanner Jaffe (1) produced some of the documents on its log, (2) expressly agreed to produce gtl work-product documents to Fo
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.
issues. DE 6353 at 5-6. This argument does not address the more basic attorney-client privileges, which have never been waived in any way. But, as Fanner Jaffe's briefing clearly explains, there has never been any waiver — either of attorney-client privilege or work-product protection — over the "key emails"
ve Order, which specifically only included emails relating to news reporters or the media. On May 7, 2012, Judge Crow entered an Order on Plaintiff Jeffrey Epstein's Motion to Compel Production of Documents from Defendant Bradley Edwards and for Sanctions stating, "Bradley Edwards shall within 30 days of the date
offender who has been sued by dozens of victims for sexual abuse of children. In the course of the above-captioned bankruptcy proceedings, in 2010, Epstein served a broad subpoena attempting to secure thousands of attorney communications by Fanner Jaffe attorney Bradley J. Edwards, Esq., who while prev
E OF AN ORDER TO SHOW CAUSE WHY FOWLER WHITE AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT,
orneys at the law firm of Fowler White Burnett, P.A. ("Fowler White")—would make a copy of the materials and return them to Fanner Jaffe. Because of Fanner Jaffe's obvious concern that 1 EFTA00799314 Case 09-34791-RBR Doc 6323 Filed 03/19/18 Page 2 of 23 Epstein or his legal counsel might misappropriate
Entities connected to both Jeffrey Epstein and Fanner Jaffe's

George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Paul Cassell
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Salt Lake City
LOCATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSON
the University of Utah
ORGANIZATIONBates
PERSONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATIONChambers
PERSONRothstein Rosenfeldt Adler
ORGANIZATION
Fowler
PERSON