Epstein Secrets

, P.A., CHAPTER 11 Debtor. INTERVENORS L.M., E.W.. AND JANE DOE'S LIST OF REOUESTED RELIEF SOUGHT

edies as the Court may find just and proper. CONCLUSION The Court should grant the three Victims' the relief requested above, including joinder in Farmer Jaffe's motion for sanctions and their own sanctions and other relief, for reasons as described in DE 6345 and DE 6357, as well as Farmer Jaffe's related pl

84112-0730 Limited Intervenor a -Counsel for E.W. and Jane Doe Jay Howell Jay Howell & Associate

tions filed in the Circuit Court. 14 EFTA00808717 C. Bankruptcy Court D.E. 6351 Date Document 04/09/18 Epstein's Response in Opposition to Farmer Jaffe's Motion for Issuance of an Order to Show Cause, etc. Page 2 "The Court should not spend its valuable time and resources on this transparent and fri

s to call into this hearing on behalf of L.M., E.W. and S.R. THE COURT: I don't MR. EDWARDS: I don'

rs, which ended up with the order that we're talking about today. Another point of clarification, Mr. Scarola says that the order was entered over Farmer Jaffe's objection. He may have had some -- the law firm may have had some concerns, but it's very clear it's an agreed order. I don't know that that makes

LL, Esquire (via telephone) On behalf of L.M., E.W. and Jane Doe EDWARDS POTTINGER, by BRITTANY HEN

have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,

g parties. See, e.g., Econ. Premier Assur. Co. v. W. Nat. Mut. Ins. Co., 839 N.W.2d 749, 753 (Minn. C

proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d

e. INTRODUCTION AND BACKGROUND Although L.M., E.W., and Jane Doe have sought to join in the motion f

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

w at the University of Utah Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Counsel for L.M.,

there had been a waiver of any privilege with regard to documents contained on the disc that permitted you to file documents that were included on Farmer Jaffe's privilege log. Ianno (Fowler White's counsel): And I want to add my objection that that has nothing whatsoever to do with the motion, the order or

ail: [email protected] Attorneys for L.M., E.W., and Jane Doe 12 EFTA00795938

OSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess Sanctions and Cost

here. Several of these victims, including L.M., E.W., and "Jane Doe," were represented by Farmer Jaff

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