Epstein Secrets

/2010 160 Notd Notice of Taking Deposition Gary Farmer 12/16/2010 161 Notd Notice of Taking Deposition

aking Deposition Notice of Taking Depo of RC Dr. Maria San Jorge 4/17/09 03/30/2009 29 Notd Notice of

ctions to Cancelled Notice of Deposition Duces Tecum of Records Custodian of Trustee Herbert Stettin January 20. 2011. And Motion For Appointment of Robert Carney as Special Master 02/28/2011 250 Resp Response To: Plaintiff's Amended Complaint 02/28/2011 251 Rntd Re-Notice of Taking Deposition None 02/28/

■., Bradley Edwards, or other former clients of Farmer Jaffee, where Edwards presently works, and to pr

urt conducted a hearing on Plaintiffs Motion to Compel and entered an Order on August 13, 2010 appointing former Broward County Circuit Court Judge Robert Carney as Special Master to review the documents responsive to the Plaintiff's subpoena served on the Trustee, to determine the applicability of any privil

ays following receipt of this order, Berger Singerman, as counsel for the Trustee, Herbert Stettin ("Trustee"), shall deliver to Gary Farmer at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Farmer Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney a

at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Farmer Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and which contains all electronically stored information ("ESI") and other documents in the Trustee's possession, respecting the

stein retained 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

ct privileged 1 EFTA00793668 information. By Order dated August 13, 2010 [DE 888] this Court ordered the documents be produced to Special Master Robert Carney for the purposes of the Special Master preparing a privilege log, and that all legal fees and costs incurred by the Special Master be paid by Epstei

contained on the discs with Bates numbers added, and will provide a set of copied, stamped documents to the Special Master and an identical set to Farmer, who will use same to create its privilege log. Farmer agrees to prepare that portion of the privilege log relating to emails on or before December

at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Fanner Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and which contains all electronically stored information ("ESI") and other documents in the Trustee's possession, respecting the

order, and it appearing for reasons explained by Farmer Jaffe its Motion for an Order to Show Cause Why

and resulting dissemination of the subject privileged materials. Such inquiry should include, but not be limited to, testimony from Special Master Robert Carney, Jeffrey Epstein, Fowler White Attorney Joseph L. Ackerman, Fowler White Attorney Lilly Ann Sanchez, Jack Goldberger, Tina Campbell, Scott Link, Ka

tein retained 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

with jurisdiction over all discovery sought from the RRA Trustee. 6. On August 13, 2010, this Court appointed former Broward County Circuit Judge Robert Carney as Special Master, who was directed to work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by J

in this court set forth in Local Rule 2090-1(A). FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

cy court [DE 672]. This filing sparked a series of motions for protective orders [DE's 818, 819, 1022]; appointment of Broward County Circuit Judge Robert Carney as special master to take all materials responsive to the subpoena from Stettin and to prepare a privilege log [DE 888]; filings of EFTA00595516

purporting to have occurred November 12, 2010? A To make sure we're on the same one, that's the email from Mr. Lichtman to Judge Carney and Mr. Farmer. Q There are two emails: one from Mr. Lichtman to Judge Carney, and one from Judge Carney to Gary Farmer. A Yes, I have seen this. Q Going to

mer, of November 4, 2010? A I don't recall having seen this. No. Q The next email in this composite is an email of November 9, 2010, first from Robert Carney to Luis Torres, with a copy to Lilly Ann Sanchez. Have you seen that email before? A Yes, I have. 2010, from Seth Lehrman to Palm Beach Reporti