Epstein Secrets

necessary intervention appearance below by E.W., L.M. and Jane Doe, while never reduced to any written By order of this Court dated March 16, 2018, Paul G. Cassell, Esq.'s request to appear pro hac vice in order to appear on behalf of the non-parties was appropriately denied pursuant to Florida Rule of Judicia

he Extraordinary Documents Remain Under Seal and No Partial Relieffrom Stay (or Relinquishment) is Necessary It is indeed curious how arduously Mr. Cassell works to ignore Epstein's continued cooperation, once a "claim" of privilege was raised, with Edwards' efforts to seal the exhibits, the disc from

f custody and ethical handling of the documents-turned-exhibits. (App. B and App. C.) "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." (App. D-2, 59:24.) Even though this Court's stay order did not occur for an enti

y" identified by Epstein's current counsel. Attempting to discern the origin of the emails (clearly legally and properly obtained by Scott Link and Kara Rockenbach), the trial judge ultimately concluded that he would deal after trial, if at all, with the how predecessor counsel, Fowler White, obtained the docu

y Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 (above for address purposes only) Att

Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell, Esq. S.J. Quinney College of Law at the Univers

client. And I can say legal counsel, Mr. Goldberger. So that's it." Hearing Trans. 64:14-19. 30. During the hearing, counsel for Epstein (Link and Rockenbach) also revealed that Fowler White was disclaiming any memory of the circumstances surrounding the creation and retention of the disc: "We have reach

cause, for representing then-minor girls sexually abused by Epstein, including L.M. 21. On March 2, 2018, Epstein, through counsel Scott Link and Kara Rockenbach, Epstein filed Plaintiff/Counter-Defendant Jeffrey Epstein's Notice of Filing of Redacted Appendix in Support of Response in Opposition to Defendan

24 25 For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH 332 S. University Street Salt Lake City, UT 84112 By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRESENT Above & Beyond Reprographics 2161 Palm Beach Lakes Boulevard, Suite 412 West Palm Beach, FL 33409 By Manu

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 INDEX Videotaped Deposition of JEFFREY EPSTEIN Page No. Direct Examination by Mr. Cassell 7 Cross-Examination by Mr. Ianno 34 Redirect Examination Mr. Cassell 39 Cross-Examination by Mr. Scarola 57 Certificate of Oath 62 Certific

7 18 19 20 21 22 23 24 25 come from 10 years and other sources. If you're going to ask him if he has any documents as a result of Link .4 Rockenbach's CD -- the CD from February of 2018, ask him that. But don't be generic and ask him if he just has documents whatsoever without any reference to

neys please announce their appearances for the record? MR. SCAROLA: Jack Scarola appearing on behalf of Bradley Edwards. MR. LINK: Scott Link and Kara Rockenbach on behalf of Jeffrey Epstein. MR. IANNO: Joseph Ianno, Carlton Fields on behalf of Fowler White. MR. GOLDBERGER: And Jack Goldberger on behalf o

Ft. Lauderdale, FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant1Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Paul Cassell Atterbury, Goldberger & Weiss, P.A. 383 S. University 250 Australian Avenue S., Suite 1400 Salt Lake City, UT 84112-0730 West Palm Beach FL 3340

iff Bradley J. Edwards Jack A. Goldberger Paul Cassell Atterbury, Goldberger & Weiss, P.A. 383 S. Univ

use proceedings and the upcoming depositions. BACKGROUND During the March 8, 2018, hearing, the Court instructed Epstein to file under seal Link & Rockenbach's copy of the disc and exhibits identified on Epstein's March 5, 2018, Clerk's Trial Exhibit List which Edwards claimed were privileged. The exhibit

ldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 cassellpalaw.utah.edu Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Jay Howell Jay

laintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730

use proceedings and the upcoming depositions. BACKGROUND During the March 8, 2018, hearing, the Court instructed Epstein to file under seal Link & Rockenbach's copy of the disc it located in Fowler White's files and exhibits identified on Epstein's Trial Exhibit List which Edwards claimed were privileged.

PAUL G. CASSELL S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Telephone [email protected] March 4, 2018 Scott J. L

s provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah. Mr. Cassell is an attorney licensed in the State of Utah and has been admitted pro hac vice in certain cases relevant to this letter. EFTA00793291 2009CA0408

L 33401 Via email: [email protected] [email protected] Re: Your Possession of Confidential and Privileged Materials Dear Mr. Link and Ms. Rockenbach: I write on behalf of three of my clients, whom I will refer to as L.M., E.W., and Jane Doe. I believe you are familiar with their identities as ch

ntroduce to Your Honor II 12 For Non-Parties L.M.. E.M. 4 Jane Doe 13 University of Utah Law Professor Paul 13 HATCH. JAMES 4 DODGE, P.C. 14 Cassell, former Federal Judge Paul Cassell, 15 who will present that matter to the court. 14 Y 16 MR. CASSELL: Good morning, Your Honor. 15 17 Since

For Non-Parties L.M.. E.M. 4 Jane Doe 13 University of Utah Law Professor Paul 13 HATCH. JAMES 4 DODGE, P.C. 14 Cassell, former Federal Judge Paul Cassell, 15 who will present that matter to the court. 14 Y 16 MR. CASSELL: Good morning, Your Honor. 15 17 Since this is an unopposed motion, it wi

-2995 EFTA00793881 5 7 2 6 9 10 11 12 13 14 IS 16 17 IS 15 20 21 22 23 24 25 an order in that regard, please. All right, Ms. Rockenbach. MS. RoCEENBACH: Thank you. Hay it please the Court. Good morning. Your Honor mentioned the barrage that the Court has received. And it's the exa

ey J. Edwards Brittany N. Henderson Edwards Pottinger LLC ue, Suite 2 3301-3268 ounse 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

issing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of

ng line of questions about his firm's review of the disc after its discovery: Q. How did she [Paralegal Tina Campbell] review the disc contents? Rockenbach (counsel for Mr. Link): I am going to object on the basis of, not only work product protection, but that this exceeds the scope of Judge Ray's orde

[email protected] Co-Counsel for Intervenors E.W., L.M. and Jane Doe Co-Counsel for Plaintiff/Counter- Defendant Jeffrey Epstein VIA U.S. MAIL Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112 [email protected] The Honorable Donald

g Epstein's counsel filed a notice of "no 2 Paul Cassell never submitted an order to the trial court on hi

exhibits to the trial 6 EFTA00793722 court's attention: "So I again want to make clear that I'm finding absolutely no fault with Mr. Link, Miss Rockenbach, Miss Campbell or anyone else from the Link and Rockenbach firm in terms of what they did. . ." (App. D-2, 61:15-18.) Indisputably, it was Epstein

Burlington and Nichole J. Segal of Burlington & Rockenbach PA. L.M., E.W. and Jane Doc arc represented by Jay Howell of Jay Howell & Associates and Paul G. Cassell of Hatch James & Dodge PC. EFTA00793764 The case is In Re: Rothstein Rosenfeldt Adler PA, case number 09-34791, in the U.S. Bankruptcy Court for

ay Howell of Jay Howell & Associates and Paul G. Cassell of Hatch James & Dodge PC. EFTA00793764 The ca

s & Lehrman PL is represented by Bradley J. Edwards and Brittany N. Henderson of Edwards Pottinger LLC. Epstein is represented by Scott J. Link and Kara Rockenbach of Link & Rockenback PA and Jack A. Goldberger of Atterbury Goldberger & Weiss PA. Edwards is represented by Jack Scarola and David P. Vitale of Se