Epstein Secrets

ppropriate Motion to Jnalism; review Motion re Adverse 21 Exhibits; follow insurance policy; .idyke and J. 'rinse 03/28/18 RJG D .lition to Farmer 2.30 908.50 J. der to show cause - C ceding 03/28/18 PVD (N . , feting Oral 2.00 0.00 A. it of Certiorari re R .s re same EFTA0079913

re same 03/17/18 SJL C( ) I Edwards' Response to ,r1 mus and Motion to 03/18/18 TLC W )esponse to our Pe s, Request for Oral '. Cassell's Joinder; fo work on it ital Appendix; work or 03/18/18 RJG R ' second round of edits tc ng 03/18/18 SJL W -sell's Joinder; work or 'o 'se to o

P • • to Petitoner's Motion 0.30 0.00 fo ld Costs 03/19/18 TLC C. • Edwards' Response 9.80 2,205.00 to mus, Request for O. P. Cassell's Joinder at rk on Motion for tinue working on cl. .very . oduction issues; work on 03/19/18 SJL W Zesponse to our 8.20 6,150.00 Pr Request for O

6366] (the "Order to Show Cause"), which directed Farmer Jaffe, Mr. Bradley Edwards, L.M., E.W., and Jane

Doe's List of Requested Relief or, in the alternative, to Conduct Limited Deposition Discovery [D.E. 6393] (the "Motion"), Response [D.E. 6397], and Joinder [D.E. 6408] thereto. On April 20, 2018, the Court entered the Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not be Held in Contem

ate Services 04/02/18 SJL Work on Responses to Farmer Jaffe's and the Intervenors' Show Cause Motions

late to opposing counsel for review in advance of hearing; work on Response to Farmer Jaffe's Motion to Show Cause in bankruptcwork on Response to Joinder filed by Intervenors ., E.W. and Jane Doe 04/03/18 SJL Work on insurance demand to Fowler White; work on Motion for In Camera Review; review pro

mental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Farmer, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundamental ambiguity simply by showing that words used in a question are ame

043 I, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

80431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511

d following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); SanvaH, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

80431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511

ted, /s/ Bradley J. Edwardk Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LE RMA , P.L.

witz"), a nonparty to this litigation, is the victim of scurrilous allegations made in Jane Doe #3 and Jane Doe #4's Motion Pursuant to Rule 21 for Joinder in the Action (the "Joinder Motion"), filed as of record at DE 279. Having no remedy in this proceeding for the harm to his reputational interest, P

following the development of a full factual record. See, e.g., Strohm, 671 at 1175 (appeal following conviction); Sarivari, 669 F.3d at 406 (same); Farmer, 137 F.3d at 1269 (appeal following conviction and partial Rule 29 dismissal) Marldewicz, 978 F.2d at 808 (appeal following conviction); cf. United

80431, at *2 (S.D.N.Y. Apr. 3, 2007), aff'd, 348 F. App'x 636, 638 (2d Cir. 2009) (first alteration in original) (quoting Werner, 620 F2d at 927). Joinder is also proper for "distinct criminal acts where they originated from a common scheme." United States v. Ying Lin, No. 15 Cr. 601 (DLI), 2018 WL 511

e defense attorneys’. Moreover, because the first time Jane Doe #3 made these contemptible allegations against Prof. Dershowitz was in her Motion for Joinder in December 2014, those allegations are irrelevant as to the inquiry of whether Jane Doe #3’s rights under the CVRA were violated at the time the NPA

offey SERVICE LIST Bradley J. Edwards Dexter Lee FARMER, JAFFE, WEISSING, A. Marie Villafafia EDWARDS, FI

the Court need look no further than Dershowitz’s counterclaim in this case. Count I of Dershowitz’s Counterclaim (styled as “False Allegations in the Joinder Motion”) contends that Edwards and Cassell should pay him damages because they “filed a pleading in the Federal Action titled ‘Jane Doe #3 and Jane D

ge 18 of 20 COUNSEL LIST SEAN D. REYES Utah Attorney General By: JONI J. JONES JOEL A. FERRE Assistant Utah Attorneys General Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsim