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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
nd by email or U.S. Mail on those parties listed on the attached service list this 19th day of March, 2018. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
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
by email or U.S. Mail on those parties listed on the attached service list this 2nd day of November, 2010. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
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
purposes only, not to imply institutional endorsement) By: /s/ Paul G. Cassell r N' Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
No.: Attorney E-Mails: Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. West Palm Beach, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link &Rockenbach P.A. West Palm Beach FL 33401 Phone: Fax: Chad P. Pugatch, Esq. Rice Pu atch Robinson Storfer & Cohen, PL
and Farmer Jaffe's Summaries of Damages for violation of the same order from this Court. See DE 6394. Accordingly, unlike the damages sought by Mr. Edwards which Epstein has specifically contested, as of this time Epstein has not specifically contested the damages sought by the Victims. 2 EFTA00810603
Florida 33322 Telephone: By: /s/ Peter E. Sha Piro Peter E. Shapiro FBN ) Attorneys for Intervenors.., M, and 10 EFTA00810611 SERVICE LIST Bradley J. Edwards FLBN Brittan N. Henderson FLBN Edwards Pottinger LLC Fort Lauderdale. FL 33301 Phone: Fax: Attorneys for Fanner, Jaffe, Weissing, Edwards, Fistos & L
y institutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. M) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
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
and by email or U.S. Mail on those parties listed on the attached service list this 19th day of July, 2010. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
ained images of 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 [El . . ." DE 1194 at 2 (emphasis added). While obscuring the fact that Epstein possessed — and so far as appears in the current fact
N 61 51) Attorneys for Intervenors.., M, and Jane Doe 12 EFTA00795956 Case 09-34791-RBR Doc 6357 Filed 04/12/18 Page 13 of 14 SERVICE LIST Bradley J. Edwards FLBN 542075 Brittany N. Henderson FLBN 118247 Edwards Pottinger LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 Phone: (954)-524-2820
7 Edwards Pottinger LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale. FL 33301 Phone: (954)-524-2820 Fax: Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Scott J. Link, Esq. Link &Rockenbach, PA. 1555 Palm Beach Lakes Boulevard Suite 301 West Palm Beach, FL 33401 Phone: F
nstitutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. 6078) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
nds therefore states as follows: Jeffrey Epstein issued a subpoena, through 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
the costs of the printing and Bates Numbering of the documents, and this Court retained jurisdiction to award sanctions on behalf of Fanner Jaffe, Edwards, or clients in the event that it was determined that Epstein or Fowler White retained images or copies of the subject documents on computer or other
or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Brad Edwards Brad Edwards SERVICE LIST Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm B
s, and by email or U.S. Mail on those parties listed on the attached service list this 14ih day of May, 2018. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
a.com Attorneys for Intervenors L.M., E.W., and Jane Doe 4 EFTA00808135 Case 09-34791-R BR Doc 6384 Filed 05/14/18 Page 5 of 6 SERVICE LIST Bradley J. Edwards FLBN 542075 Brittany N. Henderson FLBN 118247 Edwards Pottinger LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820
te 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 [email protected] [email protected] Attorneys for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehman, P.L. Scott J. Link, Esq. Link &Rockenbach, P.A. Scott @linIcrocklaw.com [email protected] 1555 Palm Beach Lakes Boulevard
t) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. 6078) [email protected] Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
22 Telephone: (954) 315-1157 By: s/ Peter E. ha iro Peter E. Shapiro FBN ) Attorneys for Intervenors.., M, and 3 EFTA00809901 SERVICE LIST Bradley J. Edwards FLBN Brittan N. Henderson FLBN Edwards Pottinger LLC Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: 954 -524-2822 Attorneys for Fanner, Jaffe,
requested relief (DE 6393) as if set forth in full herein, as well as the factual background set forth in the earlier-referenced documents filed by Edwards and Farmer Jaffe. The victims now provide this summary of their damages, reserving their right to amend this summary as events develop and discove
y institutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. M) Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
rolawpa.com Attorneys for Intervenors E.W., and Jane Doe 2 EFTA00793665 Case 09-34791-RBR Doc 6495 Filed 10/24/18 Page 3 of 4 SERVICE LIST Bradley J. Edwards FLB~ Brittany N. Henderson FLBN 118247 Edwards Pottinizer LLC Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jack Scarola, Flori
Page 3 of 4 SERVICE LIST Bradley J. Edwards FLB~ Brittany N. Henderson FLBN 118247 Edwards Pottinizer LLC Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jack Scarola, Florida Bar No.: David P. Vitale, Jr. Es Florida Bar No.: Attorney E-Mails Primary E-Mail: Attorneys for
stitutional endorsement) By: /s/ Paul G. Cassell Paul G. Cassell (Utah Bar No. klu Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 20
Entities connected to both Bradley Edwards and the Bar of the United State District Court

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
LOCATION
Salt Lake City
LOCATION
Weissing
PERSONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATIONJaffe
PERSON
S.J. Quinney College of Law
ORGANIZATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION