Epstein Secrets

LD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through counsel, hereby moves this honorable Court for an Order to Show Cause Why Fowler White and Jeffre

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 previously employed as an attorney at Rothstein Rosenfeldt Adler ("RRA") had represented a number of Epstein's victims in their civ

ained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards or his client." [DE 1194]. Remarkably, in clear and intentional defiance of this Court's order, Fanner Jaffe recently discovered that Fowler White

's files." Letter of transmittal attached hereto as Exhibit A. The subject flash drive contained three separate PDF files respectively titled: (I) "Bradley Edwards.pdf' containing 8,507 pages of emails; (2) "Epstein Searches.pdf' containing 17,348 pages of emails; and (3) "Scott Rothstein.pdf" containing 1,687 page

from the Trustee, which included documents from attorney Edwards related to Edwards' representation of the sex ab

hese issues came up, we asked Fowler White to please give us the original boxes. We got the original boxes and found the disc in a folder that says J. Carney printing on it. That's it. That's all that's on this folder." Hearing Trans. at 45:11-15. Epstein's counsel then conjectured certain speculative sce

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

Y EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs. 10 THE COURT: Yes. My understanding as I left / 11 Was going to be Edwards' Second Supplement to TRANSCRIPT OF PROCEEDINGS 12 Motion in Lunine Addressing Scope of Admissible I) Evidence, and of course in that same vein

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

s. we got 12 master. They don't went to. II the original boxes and found the disk in a folder 13 THE COURT: It's Just too late. II that says J. Carney printing on it. That's it. 16 NR. LINK: But Judge, the truth is never too II That's all that's on this folder. 15 late. 14 There's no water

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

last wok just 4 and Any Reference to Docunenta Containing 4 So my suggestion to your Honor is that wo deal 5 Privileged Materials, Listed on Edwards' Privilege o first with the procedural issue because, as I said, 4 Log. 4 that will narrow issue. significantly. And then / MR. SCAROER: Yes,

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

s. we got 12 master. They don't went to. II the original boxes and found the disk in a folder 13 THE COURT: It's Just too late. II that says J. Carney printing on it. That's it. 16 NR. LINK: But Judge, the truth is never too II That's all that's on this folder. 15 late. 14 There's no water

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

. MR. LINK: Mr. Scarola, can you for the record state -- I can see on the first page it says something. What does that say? MR. SCAROLA: It says, J. Carney, dash, Printing of CD Issue. BY MR. SCAROLA: Q Do you know whose handwriting that is? A I have no idea. Q Was this part of the documents insi

tained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards, or his client. This type of Order was essential to protect Farmer Jaffe and its client from the potential problems that could arise from the unpre

at Rothstein, Rosenfeldt, Adler ("RRA") and continued the prosecution of those civil cases against Jeffrey Epstein. When the RRA law firm imploded, Edwards joined in forming the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman ("Farmer Jaffe"), and continued prosecuting those cases. Days a

0, 2010 Order strictly precluded Fowler White from possessing, Mr. Hurley also discovered in Fowler White's possession a folder bearing the writing "J. Carney — Printing of CD issue —." This folder contained 32 printed, hard copy emails, 24 of which are currently listed on the Fanner Jaffe privilege log a

SCAROLA: Thank you, air. Your Honor, have uo decided what notions we're going to hoar? THE COURT: Yes. My understanding as I la;' was going to be Edwards' Second Supplement to Motion in Lamine Addressing Scope of Admissible Evidence, and of course in that sane vein roster'. Notice of Service of Unre

nderstand that. I otherwise, the Court retains jurisdiction to award 9 THE COURT: Titoorder eays that Fowler Mit. sanctions in favor of Farmer, Brad Edwards or his 10 will not retain any copies of 0he documents .1 client," end quote. 1i contained on the disk provided to it nor shall any • MR. LIN

es. We got 12 master. They don't want to. ii the original boxes and found the disk In a folder II THE COURT: It's just too late. 14 that says J. Carney printing on It. That's it. )4 MI. LIKE: But Judge, the truth is never too :I That's all that's on this folder. IS late. There's no watermarks,