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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
tein's sex abuse victims. Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and LM., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 4. On April 17, 2010, Epstein served a subpoena in the Epstein lawsuit upon Roths
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
ach 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 result of that subpoena was the production from the RRA trustee of approximate
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
each 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") to the RRA trustee, were 1 EFTA00808140 Case 09-34791-RBR Doc 6382 Filed 05/14
Entities connected to both Bradley Edwards and Florida Case No.

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
ORGANIZATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATIONAtterbury Goldberger & Weiss
ORGANIZATION
Jay Howell
PERSON
Jacksonville
LOCATION