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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
ding attorney client privilege and work product privilege and remain on the privilege log. RECENT EVENTS 20. On November 1, 2017, the law firm of Link & Rockenbach, P.A. entered a Notice of Appearance in the Epstein lawsuit, pending before Judge Donald Hafele (the successor to Judge Crow). As it has evolved, Epstein
privileged and not privileged, potentially responsive to a subpoena issued in the Palm Beach State Court case of Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and L.M., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"
arent violation of the Court's order was uncovered on the eve of trial of the Epstein lawsuit, which concerns a malicious prosecution claim filed by Edwards against Epstein, and which was previously set for trial on March 13, 2018.' Specifically, on March 2, 2018, Epstein, through his trial counsel Link
on of the Court's order by keeping a bates numbered CD in its files, which was later turned over the Epstein's trial counsel in the Epstein lawsuit, Link & Rockenbach, P.A. At least some of those improperly retained documents were then turned over to Epstein. Fowler White and Epstein's apparent violation of the Court's
Florida, on November 16, 2018, at 9:00 a.m. and to have with you at that time and place the following: All e-mail communications that include both Bradley J. Edwards and Scott J. Rothstein , as either a sender ("from") or recipient ("to," "cc," or "bcc"), for the period of March 1, 2009, through November 30, 2
mail communications that include both Bradley J. Edwards and Scott J. Rothstein , as either a sender ("f
tes of America do United States Attorney's Office 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach Lakes Boulevard, Suite 930, West Palm Beach, Florida, on November 16, 2018, at 9:00 a.m. and to have with you at that time and pla
Entities connected to both Bradley Edwards and Link & Rockenbach, P.A.

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONthe Southern District
LOCATION
Salt Lake City
LOCATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSON
the University of Utah
ORGANIZATIONJaffe
PERSON
S.J. Quinney College of Law
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATION
Jay Howell
PERSON
Jacksonville
LOCATION