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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
urt finds the defendant acted willfully or maliciously in disregarding the injunction, then the court may cite the defendant for criminal contempt." Mercer v. Mitchell, 908 F.2d 763, 769 (11th Cir. 1990) (citing 18 U.S.C. § 401(3) (stating, "[a] court of the United States shall have power to punish by
than 27,000 pages of e-mails, thousands of which have been produced to Epstein and only 47 e-mails which Epstein identified as trial exhibits that Edwards claim are privileged. Indisputably, no court has deemed the documents on the disc or the 47 e-mails to be attorney-client privileged, or even addres
SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer
iles for eight years. "[T]he requirements of due process in a civil contempt proceeding are flexible, varying with the circumstances of each case." Mercer v. Mitchell, 908 F.2d 763, 769 n.11 (11th Cir. 1990). The Intervenors' damages claims are fraught with material factual issues which support allowin
ate Relief [D.E. 6326] (the "Motion for Order to Show Cause"), the Responses [D.E. 6351, 6355], and the Reply [D.E. 6358] thereto. Interested Party Bradley Edwards filed a notice of joinder [D.E. 6325], and sexual assault victims, L.M., E.W., and Jane Doe, filed a Motion to Intervene [D.E. 6344] and a Motion fo
ly [D.E. 6358] thereto. Interested Party Bradley Edwards filed a notice of joinder [D.E. 6325], and sexual
, who may be represented by counsel, can introduce evidence rebutting the allegation of contempt and testify on its own behalf." Id. at 1324 (citing Mercer v. Mitchell, 908 F.2d 763, 767 (11th Cir. 1990)). The Court will refrain from considering criminal contempt, punitive sanctions, or incarceration b
more in- formation before deciding whether to quash a plea agreement that put Palm Beach billionaire Jeffrey Epstein be- hind bars for 18 months. Brad Edwards, a Hollywood attor- ney representing three girls who claim they were sexually abused by Epstein, appeared before U.S. District Judge Kenneth Marra
ctims not consulted in plea negotiations From Page Al County Jail, includes an agreement that the federal government will not prosecute Epstein. Edwards said his clients were not con- sulted when the plea deal was negotiated. The girls, each identified public- ly as a "Jane Doe," were about to be na
ohnson. New York Post. New York, N.Y.: Dec 28, 2003. pg. 012 Abstract (Document Summary) ANDRE BALAZS, 46. The ever-smiling hotelier - who owns The Mercer in Soho, Chateau Marmont and the Standard in L.A., the Raleigh in Miami, Sunset Beach on Shelter lasland, and a new place in St. Barts -just split
Epstein has said. He also owns Little St. James. a 70-acre island in the U.S. Virgin Islands. where the main house is currently being renovated by Edward Tut- tle. a designer of the Amanresorts. There is also a 56.8 million house in Palm Beach, Florida. and a fleet of aircraft: a Gulfstrcam IV. a he
ohnson. New York Post. New York, N.Y.: Dec 28, 2003. pg. 012 Abstract (Document Summary) ANDRE BALAZS, 46. The ever-smiling hotelier - who owns The Mercer in Soho, Chateau Marmont and the Standard in L.A., the Raleigh in Miami, Sunset Beach on Shelter lasland, and a new place in St. Barts -just split
Edelman Florian Eder Richard Edgar Agustin E. Edwards Robert Edwards John Ehara Felix Ehrat Barry E
cial Officer Morgan Stanley USA Peter Portin Chief Financial Officer XL Group Plc USA Julio Portalatin President and Chief Executive Officer Mercer (MMC) USA Rob Portman Senator from Ohio (Republican), USA Adam S. Posen President Peterson Institute for USA International Economics Eduard
277—78 White House appointments and, 4, 36, 86-87, 89, 189, 285 Barra, Mary, 88 Barrack, Tom, 27-29, 33, 42, 85, 233, 240 Bartiromo, Maria, 205 Bass, Edward, 56 Bayrock Group, 100-102 Bedminster Golf Club, 165, 213-14, 216, 287-94, 297, 302, 307 Beinart, Peter, 297 Benghazi, 97 Berkowitz, Avi, 143 Berlusc
1, 235, 258, 263-68, 276-77, 288-89, 298-99, 304-5 McNerney, Jim, 88 Meadows, Mark, 161, 163, 171 Medicare, 165 Melton, Carol, 78 Mensch, Louise, 160 Mercer, Rebekah, 12, 58-59, 121, 127, 135, 139, 177-80, 201, 208, 309 Mercer, Robert, 12, 58-59, 112, 177-80, 201, 309 HOUSE_OVERSIGHT_020130 Mexico, 39,
Entities connected to both Bradley Edwards and Mercer

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATION
Bill Clinton
PERSON