Epstein Secrets

y Blvd. #250 Jacksonville, FL 32211 (904) 680-1234 Paul G. Cassell 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) Attorney E-Mail: [email protected] Attorneys for L.M., E.W., and Jane Doe EFTA00795944

7,000 emails and the creation of a privilege log, which has been rendered meaningless due to the violation; this task required the time of numerous Farmer Jaffe employees and in total well over 100 hours of time. Fanner Jaffe seeks reimbursement for only a fraction of that time: 40 hours of attorney time at

EMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS AND FOR OTHER APPROPRIATE RELIEF Farmer Jaffe Weissing Edwards Fistos & Lehrman ("Farmer Jaffe"), through counsel, hereby files this Summary of Damages in Support of Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Sho

Avenue S., Suite 1400 West Palm Beach. FL 33401 MOW Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm B

and its insurer, (4) Intervenors Jane Doe, L.M. and E.W. (collectively, "Intervenors"), and (5) Farmer Jaffe Weissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Mediation Participants"), to participate in mediation subject to this Agreed Mediation Confidentiality Order. The Court, here

alian 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 Howell & Associates 644 Cesery Bl

Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRODUCTION Defendant, Bradley J. Edwards, along with Farmer Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a N

hone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 Paul G. Cassell, Esq. S.J. Quinney College of Law University of Utah 332 S. 1400 E. Salt Lake City, UT 85112 Telephone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 A. Marie Villafafia, Esq. AUSA United States Attorney's Office 500 S.

:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 4 of 4 CASE NO: 08-80736-CIV-MARRAMATTHEWMAN SERVICE LIST Brad Edwards, Esc' Farmer Jaffe, Et Al. 425 N. Andrews Avenue Suite 2 Ft. Lauder - 268 Telephone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 Paul G. Cassell, Esq.

-80893-MARRA/JOHNSON Epstein's MPO, Objections and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac flee 33 2 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax Casselto(a)law.utakedu Co-Counselfor Plaintiff Respectfidly submitted, /s/ Joseph L Ackerman. Jr. Jose

ldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before

pursuant to court order dated April 3, 2018. Paul G. Cassell, Esq. S.J. Quinney College of Law at the University of Utah 332 S. University St. Salt Lake City, UT 84112 Telephone: (801) 585-5202 (above for address/contact purposes only, not to imply institutional endorsement) By: /s/ Paul G. Cassell Pa

ive an opportunity to take discovery (in the form of interrogatories, requests for admission and production, as well as depositions as requested by Farmer Jaffe) on this important subject. 3. A DIRECTION THAT EPSTEIN WRITE A LETTER OF APOLOGY IS APPROPRIATE. The Victims have also requested that Epstein (a

0893-MARRA/JOHNSON Epstein's MPO, Objections and Integrated Memo of Law et al. Paul G. Cassell, Esq. Pro Hac Vice • 33 2 South 1400 E, Room 101 Salt Lake City, UT 84112 Co-Counsel for Plaintiff Respectfully submitted, /s/ Joseph L Ackerman. Jr. Joseph L Ackerman, Jr. Fla. Bar No. 235954 Lilly Ann Sanc

ldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before

r Jaffe Weissing Edwards Fistos and Lehrman (“Farmer Jaffe”). I was thus with RRA for less than one year. In July 2010, along with other attomeys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my three clients Jj. WW... and Jane Doe in their lawsuits against Epstein. On July 2

Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 {e) Paul G. Cassell, Esq. Pro Hace Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 Co-