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

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

30 Marc S. Nurik, Esq. LAW OFFICES OF MARC S. NURIK One E. Broward Boulevard, Ste. 700 Ft. Lauderdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, Ste. 2 Ft. Lauderdale. FL 33301-3268 Attormeys for Bradley J. Edwards EFTA00808548

on and the procurement of minors to engage in prostitution and further agreed to be registered as a sex offender (App.13, p.133). Bradley Edwards ("Edwards") is a civil attorney who represented multiple victims of Epstein's serial abuse of children. Edwards filed three civil actions against Epstein in

derdale. FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, St

ber 2017 Motion to Continue] said, "We have heard the Court loud and clear, now we" — Link and Rockenbach — "are on the case, with support from the Gunster firm, and we will not allow the same type of conduct that transpired earlier, which the Court was critical of, [to] happen again." That pledge to

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

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

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

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

copy of this Engagement Memorandum. 2. Scope of Services. I am being engaged to serve as a consulting expert regarding issues raised by Defendant Bradley Edwards' counterclaim against Mr. Epstein in the above- referenced matter, as well as on such other issues as you and I may agree. I will familiarize myself

ert regarding issues raised by Defendant Bradley Edwards' counterclaim against Mr. Epstein in the above- r

. 561.598.6800 Fax 561.598.6801 www.culversmithlaw.com D. Culver Smith Ill ceu 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Th

ng factual and legal support for the opinions to which I may testify and in defining 5019-009.cngmtmcm.02 EFTA00795577 ENGAGEMENT MEMORANDUM TO: Gunster, Yoakley & Stewart, P.A. RE: Epstein v. Rothstein November 2, 2017 Page 2 of 5 potential areas for inquiry. My testimony will be as an objective

. CML TRIAL & APPELLATE LAW December 1, 2017 Via Email Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 100.001 1555 Palm Beach Lakes Blvd , Suite 301 West Palm Beach, Fronde 33401 T 561.727 3600 F 561.727 3601 Dear Jeffrey: Attached pl

are summary of Judge's ruling from the October 3, 2017 hearing 1.90 750.50 re J. Epstein's Motion to Overrule Objections and Compel B. 395.00/hr Edwards to answer questions in preparation of B. Edwards' upcoming deposition KBR Review executed Order Specially Setting Hearing from Judge Donald 0.10

nue Trial KBR Telephone call with J. Scarola re J. Epstein's request for continuation of trial and Pre-Trial Stipulation KBR Meet with trial team, Gunster counsel and J. Epstein at J. Goldberger's office to discuss trial strategies, client testifying at trial and probable cause at commencement of acti

c.it JUDGE DONALD HAFELE Circuit Judge Copies furnished to: F F F F F F F F F F F F F F F F F F F F F Andrew A. Harris (~~) Bradley James Edwards (ffillia Fred Haddad an) John Scarola irsETPH \CKERMAN JR Maria Kelchian ~la) Matthew D Weissing II~M) Pi 4IMP M RUM INC- roN service@jurytri

ENDANT JEFFREY EPSTEIN'S MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST AND SUPPLEMENT TO MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST Bradley J Edwards ("Edwards"), by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Motion to Allow Amendment to Exhibit

ber 13, 2017, Plaintiff retained new trial counsel, who appeared in the case on November I, 2017. Plaintiff also retained a team of lawyers from the Gunster law firm as trial support. None of the things Plaintiff is asking for in this Motion is based on lack of manpower. Even using all of these resource

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETI

derdale, FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, St

er 13, 2017, Plaintiff retained new trial counsel, who appeared in the case on November I, 2017. Plaintiff also retained a team of lawyers from the Gunster law firm as trial support. None of the things Plaintiff is asking for in this Motion is based on lack of manpower. Even using all of these resources

Darren) • Tom/Tim — work on verdict forms, statement of facts and case summary for focus group (by 10/27) Other To Do Items • Set deposition of Edwards' Expert • Draft Mediation Statement (11/10 to mediator — circulate draft in advance) • Review Exhibit and Witness Lists - Gunster • List object

stipulate in writing to facts and issues, prepare a Pre-Trial Stipulation and list objections to exhibits [30 days prior to trial] 11/10/17 DEPO: Bradley Edwards @ Searcy Denny 11/10/17 DUE: Certificates of Authority for Mediation; Mediation Statement 11/12/17 DEADLINE: Bradley Edwards to appear for deposi

et up meetings with Critton and Ackerman (Jack/Darren/Scott/David/Kara) and also ensure we get their files • Tonya/Jack — to send us their files — Gunster will arrange copy service (I have already coordinated with Chet for his files; Crystal/Gunster to coordinate today about getting Tonya's and Jack's