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FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended Order [D.E. 1068] related to the production of documents requested by Jeffrey Epstein and to Compel Jeffre
in and to Compel Jeffrey Epstein to Pay for the Production of all Documents which he has requested, and in support thereof, states as follows: 1. Brad Edwards, an attorney employed by Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe Weissing"), has represented LM and other women who
all Documents which he has requested, and in support thereof, states as follows: 1. Brad Edwards, an attorney employed by Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe Weissing"), has represented LM and other women who allege that they were sexually exploited, sexually abused
s. 2. Epstein filed a frivolous lawsuit against Attorney Edwards and his client LM, who is one of Epstein's forme
. Shraiberg, Esq. 2385 NW Executive Drive Suite 300 Boca Raton, Florida 33431 [email protected] (VIA CM/ECF and EMAIL) Henry S. Wulf, Esq. CARLTON FIELDS, P.A. 525 Okeechobee Blvd., Suite 1200 West Palm Beach, Florida 33401 E-Mail: [email protected] (VIA CM/ECF and EMAIL) EMESS Capital, LLC
tance that you discussed the contents of the documents with? A I don't recall anybody except my attorneys. Q Did you have any communication with Bradley Edwards regarding the content of those documents? A I don't recall. Q Since receiving those documents, did you have any communication with Bradley Edwar
2 13 14 15 16 17 18 19 20 21 22 23 24 25 Rothstein, Rosenfeldt, Adler PA; Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which case? MR. SCAROLA: This is the subpoena duces tecum issued in t
te Court issues and not to be considered in the Show Cause proceedings. 2 EFTA00793402 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 3 of 97 EDWARDS: ... The representation was made on the record by Mr. Link that he provided it within his law firm and his client, that being Mr. Epstein. When fur
cribe the contents? A When you say documents, you mean pages? I'm sorry? Q Yes, sir. Pages. A Well, I can remember the emails with respect to Brad Edwards -- Q Excuse me. Pardon me. I'm stopping you, sir. That's no responsive to my question. And I don't want you on this record to be disclosing the co
BERGER, ESQUIRE For Defendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRES
tance that you discussed the contents of the documents with? A I don't recall anybody except my attorneys. Q Did you have any communication with Bradley Edwards regarding the content of those documents? A I don't recall. Q Since receiving those documents, did you have any communication with Bradley Edwar
a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which case? MR. SCAROLA: This is the subpoena duces tecum issued in the
ed from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which case? MR. SCAROLA
.M., E.W., and Jane Doe 10 EFTA00793508 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 11 of 165 Attorneys for Jeffrey Epstein SERVICE LIST Bradley J. Edwards FLBN Brittany N. Henderson FLBN 118247 Edwards Pottinger LLC Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jack Scarola, Esi= Fl
BERGER, ESQUIRE For Defendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH By PAUL G. CASSELL, ESQUIRE
ulted her when she was a minors. The parties recently reached a confidential settlement of this lawsuit on the eve of trial. 4. Movant's counsel, Brad Edwards was employed by RRA. During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained
d a confidential settlement of this lawsuit on the eve of trial. 4. Movant's counsel, Brad Edwards was employed by RRA. During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained substantial parts of client case files and investigative
eeking production from Trustee Herbert Stettin of Attorney Edwards case files and investigative files which relate
Fax: 561-998-0047 [email protected] EFTA00780315 Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 10 of 10 Henry S. Wulf, Esq. (VIA EMAIL) CARLTON FIELDS, P.A. 525 Okeechobee Blvd., Suite 1200 West Palm Beach, Florida 33401 Telephone: (561) 659-7070 Facsimile: (561) 659-7368 E-Mail: hwulf@carltonl
to form. THE WITNESS: All the emails between Fowler White and Judge Carney which referenced the handling of the disc have been produced. BY MR. EDWARDS: Q Were there emails between Fowler White and Judge Carney that reference issues other than the handling of the disc that you reviewed? A I bel
erstand why you think these particular documents -- because all I've heard you say is they have Brad Edwards' name. I have hundreds of emails with Brad Edwards' name on it that have been produced in this case. I have thousands of pages of documents that have been produced in this case with Bates stamp num
at the top, I see there are 30 others documents. Turn the page, go flip the page to page two, electronically through the folder. That's when I see the Brad Edwards email and the number at the bottom. I go to page three, I see another Brad Edwards email, number at the bottom. The fact that they were Brad Edwar
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TO: JAMES N. HURLEY, ESQUIRE c/o JOSEPH IANNO, ESQUIRE CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 RE: ROTHSTEIN ROSENFELDT ADLER, P.A. At the conclusion of your deposition give
hearing before December 28, 2010 and moves to briefly stay enforcement of its Order [DE 1068] compelling LM and her counsel Fanner, Jaffe, Weissing, Edwards, Fistos, & Lehrman, P.L. ("FJW") to produce a privilege log in order to permit the state court: (1) to first rule on the pending motions for summar
of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for conduct that allege
Esq. Government Center 115 South Andrews Avenue Fort Lauderdale, FL 33301 E-Mail: [email protected] (VIA CM/ECF and EMAIL) Henry S. Wulf, Esq. CARLTON FIELDS, •. 525 Okeechobee Blvd., Suite 1200 West Palm Beach. Florida 33401 E-Mail: (VIA CM/ECF and EMAIL) EMESS Capital, LLC do Bruce A. Katzen, Esq.
: Same. BY MR. CASSELL: Q Did you have any reason to slant your testimony so it would be biased against any other part in this matter, including Bradley J. Edwards? MR. LINK: Same. BY MR. LINK: Q Isn't it true, sir, that you have substantial reasons to give inaccurate information to the answer to Palm Beac
ircumstances, absent some specific prohibition by the court with regard to those subject matters. MR. LINK: Well, you have finished on behalf Mr. Edwards. Are you now assisting Mr. Cassell and L.M. as their counsel? MR. SCAROLA: Oh, no. MR. LINK: You have already said you were done, Mr. Scarola. M
RE EDWARDS POTTINGER LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 By Bradley Edwards, Esquire (Telephonically) For Fowler White: CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE Palm Beach Reporting Service, Inc. 561-471-2995
ACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite West Palm Beach, FL 33401 301 By SCOTT J. LINK, ESQUIRE 5 By JENNIFER LETTMAN, ESQUIRE 6 For Bradley Edwards: 7 SEARCY, DENNEY, SCAROLA, BARNHART & 8 SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard 9 West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE
0 21 22 23 24 25 INDEX Videotaped Deposition of JAMES N. HURLEY, ESQUIRE Page No. Direct Examination by Mr. Scarola Cross-Examination by Mr. Edwards Cross-Examination by Mr. Link Redirect Examination by Mr. Scarola Recross-Examination by Mr. Link Further Redirect Examination by Mr. Scarola Re
11 EDWARDS POTTINGER LLC 12 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 13 By Bradley Edwards, Esquire 14 For Fowler White: 15 CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 16 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE 17 18 ALSO PRESENT 19 Above & Beyond Repr
Entities connected to both Bradley Edwards and CARLTON FIELDS

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONRobert D. Critton
PERSON
Prince Andrew
PERSONthe Southern District
LOCATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSONDarren Indyke
PERSONJaffe
PERSON
S.J. Quinney College of Law
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION
New York
LOCATION