Epstein Secrets

80 855.00 Relief to address D. Indyke's comments; work on Response in Opposition to B. Edwards' Summary of Damages; follow up with C. Pugatch and J. Goldberger re potential new date for J. Epstein's deposition; work on Motion to Compel B. Edwards to Identify Bates Numbers of Documents Produced EFTA0079406

s 06/01/18 TLC Work on scheduling J. Epstein's deposition; work on dates for same; multiple communications with client, C. Pugatch, D. lndyke and J. Goldberger re availability; work on proposed Order on J. Epstein's deposition to incorporate D. Indyke's suggested edits; follow up with client and counsel o

onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried in order to interview jurors; research Farmer

ke? Rockenbach: Objection. Work product, attorney-client, and beyond the scope of Judge Ray's order. Please do not answer. Q. Same question as to Jack Goldberger. Rockenbach: Same objection. Same instruction. (Link 62:14-6:7.) EFTA00794263 Again, this line of questioning as to whom Mr. Link spoke with con

ease do not answer. Q. Same question as to Jack Goldberger. Rockenbach: Same objection. Same instruction.

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

aw.com 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire [email protected]; [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 334

-727-3601 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire [email protected]; [email protected]

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

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, Kara Rockenbach, and the currently unidentified attorneys that Mr. Link has represented are also working on this case o

an, Fowler White Attorney Lilly Ann Sanchez, Jack Goldberger, Tina Campbell, Scott Link, Kara Rockenbach, and

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

80 855.00 Relief to address D. Indyke's comments; work on Response In Opposition to B. Edwards' Summary of Damages; follow up with C. Pugatch and J. Goldberger re potential new date for J. Epstein's deposition; work on Motion to Compel B. Edwards to Identify Bates Numbers of Documents Produced EFTA0079917

s 06/01/18 TLC Work on scheduling J. Epstein's deposition; work on dates for same; multiple communications with client, C. Pugatch, D. Indyke and J. Goldberger re availability; work on proposed Order on J. Epstein's deposition to incorporate D. Indyke's suggested edits; follow up with client and counsel o

onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried In order to interview jurors; research Farmer

s of these privileged documents?," counsel for Epstein replied, "I just said my client. My law firm and my client. And I can say legal counsel, Mr. Goldberger. So that's it." Hearing Trans. 64:14-19. 30. During the hearing, counsel for Epstein (Link and Rockenbach) also revealed that Fowler White was dis

aw.com 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esq. [email protected]; [email protected] Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401

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

01 Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australia

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

r the contents of these privileged documents? Mr. Link replied, I just said my client, my law firm and my client, and I can say legal counsel, Mr. Goldberger. So, that's it. So we now know that this information that was improperly obtained was disseminated not only to OUELLETTE & MAULDIN COURT REPORTER

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

view same for 5.80 1,305.00 Court's ruling; work on revisions to proposed Order re J. Epstein's limited deposition; follow up with D. Indyke and J. Goldberger re review of same; work on Motion to Strike; finalize Notice of Hearing for trial docket 05/25/18 RJG Initial review of S. Rothstein's Motion to

g 2.10 829.50 Motion to Strike Intervenors' List of Requested Relief 05/22/18 RJG In Bankruptcy Proceedings, review/analyze (1) 3.50 1,382.50 Farmer Jaffe's Motion for Order to Show Cause-Contempt; (2) Intervenors' Joinder in Motion for Order to Show Cause; (3) Court's Order to Show Cause-Contempt; and