Epstein Secrets

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

hat Edwards claims are privileged and are currently under seal may be unsealed at the mediation and shown by Epstein's attorneys to the mediator and Fowler White's attorneys. Edwards' counsel shall bring Edwards' copy of the 47 e-mails to the mediation for this limited purpose. 8. The use of the 47 e-mails d

Jaffe who have the full authority to settle without further consultation shall appear at the mediation in person. Furthermore, a representative of Fowler White's insurance carrier who has full authority to settle in an amount up to its policy limits without further consultation shall appear at the mediation i

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 33401 [email protected] Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe Co-Counsel for Plaintiff

ler White had in its files and turned over in February 2018 to Epstein's current trial counsel, Link & Rockenbach. The Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention.

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

d "Epstein Bates Stamp" that Fowler White had in its files and turned over to Link & Rockenbach in February 2018. The Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention.

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 Limited Intervenor Co-Counsel for S. E.W. and Jane Doe Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm Beach

IS MATTER came before the Court upon the agreement of Jeffrey Epstein ("Epstein") and Fowler White Burnett ("Fowler White") concerning the return of Fowler White's original files. The Court, being advised of the agreement of Epstein and Fowler White, and being otherwise advised in the premises, it is hereby O

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 [email protected] Limited Intervenor Co-Counsel fora, E.W. and Jane Doe Scott J. Link Kara Berard Rockenbach Link & Rockenba

IS MATTER came before the Court upon the agreement of Jeffrey Epstein ("Epstein") and Fowler White Burnett ("Fowler White") concerning the return of Fowler White's original files. The Court, being advised of the agreement of Epstein and Fowler White, and being otherwise advised in the premises, it is hereby O

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 EFTA00808126 Case 09-

Order did not "sit in a box" for the past eight (8) years. This fact, however, was only uncovered at the October 19, 2018 deposition duces tecum of Fowler White's corporate representative, which was conducted after Epstein's deposition on October 13, 2018. Thus, the Court should not excuse Epstein from attend

r Ja,ffe, Weissing, Edwards, Fistos & Lehrman, a Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 casse11p08aw.utah.edu Peter E. Shapiro Shapiro Law 8551 West Sunrise Boulevard, Suite 3000 Plantation, FL 33322 Counsel for ,

ts on a disc, not sexual abuse claims. Simply, the Intervenors seek money damages for significant emotional distress because a disc sat in a box in Fowler White's files for eight years. Because the Intervenors appear to have failed to present this Court with requisite proof of their damages, this Court can eit

tralian Avenue S., Suite 1400 West Palm Beach FL 33401 Co-Counsel for Plaintiff/Comter-Defendant Jeffrey Epstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 Limited Intervenor Co-Counsel for M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonvi

federal civil contempt relating to the alleged violations of the November 2010 Agreed Order. Specifically, Edwards may take the depositions of (1) Fowler White's representative about the chain of custody of the discovery documents; (2) Epstein about his knowledge or possession of the disc or documents pre-20

AVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe HATCH, JAMES 4 DODGE, P.C. 10 Nest Broadway, Suite 400 Salt Lake City, UT 84101 By PAUL G. CASSELL, ESQUIRE 5 For Jeffrey Epstein: 4 ATTERBURY, GOLDBERGER 4 WEISS, P.A. 250 Australian Ave. South, Suite 1400 West

K: And I agree with that. The, 12 Lieges or copies of said documents be retained in bankruptcy court reserved that. ghat I'm 13 the memory of Fowler White's copies. And we .4 suggesting to the Court is I don't think it's as le already went through the sanctions. ., clear as Mr. Scarola said. And

17 18 19 20 21 22 23 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

Judge Ray's order. BY MR. CASSELL: Q What does paragraph four mean, Mr. Epstein? A It says Scott Link informed me that he had located a disc in Fowler White's files labeled "Epstein Bate Stamp" -- quote, Epstein Bate Stamp. Q Please tell me all that he informed you of. Palm Beach Reporting Service, Inc.