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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
orneys at the law firm of Fowler White Burnett, P.A. ("Fowler White")—would make a copy of the materials and return them to Fanner Jaffe. Because of Fanner Jaffe's obvious concern that 1 EFTA00799314 Case 09-34791-RBR Doc 6323 Filed 03/19/18 Page 2 of 23 Epstein or his legal counsel might misappropriate
a E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009-CA-040800XXXXMBAG In re Rothstein Rosenfeldt Adler, P.A. U.S. Bankruptcy Court, Southern District of Florid
ter, however, felt comfortable asserting privilege claims on behalf of Bradley Edwards' clients and the task was assigned to Farmer Jaffe (where Mr. Edwards was a partner). In order to conduct the review, Farmer Jaffe wanted the 27,000 pages printed and Bates stamped so it could segregate out alleged pr
ained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Fanner, Brad Edwards or his client [L.M.j. As has been documented, during our review of Fowler White's files in January 2018, we found a disc labeled "Epstein Bate Sta
pursue production of them further solidifies Mr. Epstein's malpractice claims. While approximately 1,600 documents from the disc were identified on Fanner Jaffe's privilege log, because Fanner Jaffe (1) produced some of the documents on its log, (2) expressly agreed to produce gtl work-product documents to Fo
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
issues. DE 6353 at 5-6. This argument does not address the more basic attorney-client privileges, which have never been waived in any way. But, as Fanner Jaffe's briefing clearly explains, there has never been any waiver — either of attorney-client privilege or work-product protection — over the "key emails"
T OF FLORIDA 2 THE COURT: Good afternoon. Please be 2 3 4 IN RE: CASE NO. 09-3479I-RBR 3 4 seated. MR. SCAROLA: Good afternoon. 5 5 MR. EDWARDS: Good afternoon, your Honor. ROTHSTEIN ROSENFELDT ADLER, PA, 6 THE COURT: All right. Court calls the 6 7 matter of Rothstein Rosenfeldt & Adler.
3 2 can come up to the mic. 4 SEARCY DENNY SCAROLA BARNHART & SHIPLEY. by 3 MR. SCAROLA: Yes, excuse me. JACK SCAROLA. Esquire S On behalf of Bradley J. Edwards 4 MR. EDWARDS: I was just introduced by 6 5 Mr. Scarola. Brad Edwards on behalf of Farmer Jaffe. EDWARDS PaITINGER. by 7 BRADLEY J. EDWARDS. E
ended up with the order that we're talking 14 about today. IS Another point of clarification, Mr. Scarola 16 says that the order was entered over Fanner Jaffe's 17 objection. He may have had some — the law firm may have 18 had some concerns, but it's very clear it's an agreed 19 order. I don't know that th
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
TA00793669 confidentiality is breached or some residue or image of our documents remains at [Fowler White]." Special Master Carney took offense to Fanner Jaffe's insinuation that Jeffrey Epstein or any member of his legal team might look at the documents that were being printed at Fowler White or might retai
Entities connected to both Bradley Edwards and Fanner Jaffe's

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
LOCATION
Weissing
PERSONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATIONRothstein Rosenfeldt Adler
ORGANIZATION
Scott J. Link
PERSON
Fowler White Burnett
ORGANIZATIONE.W.
PERSON