Epstein Secrets

n 19 court to Fowler White for one purpose and one 20 much of the rest of the argument becomes 20 purpose only; and that was to print them out, Bates 21 irrelevant. 'here are, however, very significant 21 steep then so that they could be turned over for 22 substantive issues if the procedura

ware divided into three different 12 thin is 27,000 e-mails, they want than, they should 12 categorie➢. 13 be responsible for printing than and Bates stamping 12 THE COURT: And chat wa➢ December 102 14 them and delivering those printed and Bates stamped 14 M. SCAMLA: Decenbar Bch of 2010. IS

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

n 19 court to Fowler White for one purpose and one 20 much of the rest of the argument becomes 20 purpose only; and that was to print them out, Bates 21 irrelevant. 'here are, however, very significant 21 steep then so that they could be turned over for 22 substantive issues if the procedura

ware divided into three different 12 thin is 27,000 e-mails, they want than, they should 12 categorie➢. 13 be responsible for printing than and Bates stamping 12 THE COURT: And chat wa➢ December 102 14 them and delivering those printed and Bates stamped 14 M. SCAMLA: Decenbar Bch of 2010. IS

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

n pertinent part as follows: [T]he law firm of Fowler White Burnett, ■., will print a hard copy of all of the documents 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 Fanner, who will use same to creat

der. 2. Included within that submission was extensive internal email correspondence from Edwards' time as an attorney at Rothstein, Rosenfeldt and Adler. These emails were admittedly obtained from a CD that Epstein's current counsel acquired from its predecessor counsel, Fowler White. 3. At least

y 3:16 25:18,20 27:8,23 28:6 according 7:20 27:13 apparently 14:10 27:21 33:16,18 35:1 caption 50:12 28:8,16 29:16 31:11 27:25 appeals 21:14 Bates 11:5 12:13,22 CARLTON 2:13 43:14,25 44:5 45:5 actually 29:12 33:13 appear 48:13 13:25 26:8 Carney 12:23 15:4 26:8 clearly 14:20 17:16 40:12 a

11:24 carte 32:1 Clerk 6:1 22:12 42:23 address 23:4 33:11 appears 7:16 8:3 before 1:13 9:22 13:20 case I:4 4:24,25 5:6 46:21,24 47:13 48:2,4 Adler 1:5 3:7 11:21 appellate 21:14,16,19 20:7,22 21:12 31:4 13:19 24:23 26:24 48:7 49:5 administrative 12:22 21:20 23:14 35:2 36:15 44:21 29:17 31

tein, who had agreed to pay directly all such fees and costs. It was then determined that the number of documents that would need to be printed and Bates stamped exceeded 27,000, which would have resulted in significant costs to the Farmer Jaffe law firm. Consequently, Farmer Jaffe requested the Cour

ctims of Jeffrey Epstein's serial molestation of dozens of young children. In 2009, Brad Edwards took a job as an attorney at Rothstein, Rosenfeldt, Adler ("RRA") and continued the prosecution of those civil cases against Jeffrey Epstein. When the RRA law firm imploded, Edwards joined in forming the l

ask was assigned to Farmer Jaffe (where Mr. Edwards was a partner). In order to conduct the review, Farmer Jaffe wanted the 27,000 pages printed and Bates stamped so it could segregate out alleged privileged and unresponsive documents. Farmer Jaffe, however, did not want to incur the cost of reproduci

to rest once and for all. A. Negligent Retention of Disc During its representation, Fowler White pursued production from the Rothstein Rosenfeldt Adler firm's ("RRA") Bankruptcy Trustee in response to a Subpoena served by the Burman Critton firm. The Trustee assembled approximately 27,000 pages of e

face of Edwards' privilege log, Epstein has no way to determine whether the work product privileges claimed are fact or opinion work product. (See Bates . (Ex. F). It is essential that sufficient information be provided by Edwards to distinguish between fact and opinion work product because Epstein

The critical nature of these documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet. (Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he

flection of the prior testimony. It has no predicate. There was no reference about having heard about these cases from Brad. The names mentioned were Adler, possibly Farmer, possibly Jaffe. BY MS. HADDAD: Q. Once Brad started working at the firm, you've already testified you already knew about these Ep

Q. And there's -- give me one second, Scott, sorry. What was the date that complaint was filed? A. What's the last page of the complaint, what's the Bates number? Q. The last page is 234. I'm sorry, 263 would be the last page of the complaint. [The Complaint referred to was marked for identification as