Epstein Secrets

issue through some affirmative act for his own benefit, the privilege will not be allowed to protect against disclosure of such information. In re Campbell, 248 B.R. 435 (M.D. Fla. 2000). Here, Edwards has made these underlying cases in which he represented these plaintiffs against Epstein the central i

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

issue through some affirmative act for his own benefit, the privilege will not be allowed to protect against disclosure of such information. In re Campbell, 248 B.R. 435 (M.D. Fla. 2000). Here, Edwards has made these underlying cases in which he represented these plaintiffs against Epstein the central i

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

Epstein's responses 225.00/hr LD Work with T. Campbell to assemble a discovery package to be 0.50 112.

ist to identify and highlight highly 225.00/hr prejudicial documents for use at hearing; assemble additional items for hearing; work on summary of E.W. case against J. Epstein; work on locating equipment for hearing; prepare Notice of Supplemental Authority to our Objection to B. Edwards' Request f

hich this Court should reject. The trial court specifically found, "I'm not finding fault with anything you [Scott Link] or Miss Rockenbach or Miss Campbell did. That's not the issue. You've done your job." 2 EFTA00805459 (App. D-2, 59:24).2 The heightened and false sense of urgency exhibited by Paul

f from Stay with Request for Expedited Consideration" and as grounds states: Introduction No legal standing or basis exists for non-parties, L.M., E.W., and Jane Doe, to "join" any appellate motion or action by Edwards.' The unnecessary intervention appearance below by E.W., L.M. and Jane Doe, whil

ppellant 19 EFTA00793711 already will have been forced to trial in violation of the rule. [e.a.] Gawker Media, LLC, 170 So. 3d at 131. See also Campbell v. Wells Fargo Bank, N.A., 204 So. 3d 476, 479 (Fla. 4th DCA 2016) (citing Gawker, and stating: "In that context, the appellate remedy was deemed i

t court. 2 At the March 8, 2018 hearing, University of Utah Law Professor, Paul G. Cassell, Esq., appeared pro hac vice below for non-parties L.M., E.W. and Jane Doe, on a limited confidentiality issue not before this Court. On behalf of non-parties, L.M., E.W. and Jane Doe, Mr. Cassell filed an Uno

its discovery: Q. How did she [Paralegal Tina Campbell] review the disc contents? Rockenbach (counsel

or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Counsel for L.M., E.W. and Jane Doe Niall T. McLachlan Carlton Fields Jorden Burt, P.A. Isaac M. Marcushamer Coun

kenbach, PA did nothing wrong relating to its discovery and use of the disc: • "I'm not finding fault with anything you or Miss Rockenbach or Miss Campbell did. That's not the issue. You've done your job." (March 8, 2018, Aft. Tr. 59:1-4.)5 • "So I again want to make clear that I'm finding absolutely n

ls are attorney-client privileged communications between Edwards (or any other co-counsel) and Edwards' and Mr. Cassell's three tort clients (L.M., E.W. or Jane Doe). Rather, the majority of the documents are e- mails among attorneys and staff within RRA, with Mr. Cassell, and with media sources and d

roy M. Bermudez 225.00 0.40 0.00 TLC Tina L. Campbell 225.00 160.90 36,202.50 PVD Debi J. Mackey

n, and outline Response in Opposition 04/03/18 PVD [No Charge] Work on hearing binder re Farmer l e 's Motion to Show Cause, Edwards' Joinder, , E.W. and Jane Doe's Joinder and Motion to ervene 04/03/18 PVD [No Charge] Work on exhibit of comparison of privilege log for in camera inspection; wor

ided a sworn affidavit from certified paralegal Tina L. Campbell that she had obtained these materials from Fowler White's files. Specifically, Ms. Campbell attested under oath that on January 10, 2018, she had reviewed approximately 36 boxes of Fowler White's Epstein files at Fowler White's Miami, Flori

to have dealt with this issue head on because of the apparent implications of same." Hearing Trans. at 60:20-61:14. 33. Counsel for victims L.M., E.W., and Jane Doe also asked Judge Hafele to order Fowler White to explain who they had distributed the confidential materials to. Judge Hafele indicat