Epstein Secrets

ould not maintain any copies: Mlle 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 Farmer, who will use same to creat

l Relief from Stay and requested expedited consideration. Request for Expedited Consideration At issue is an effort by the trial court judge, Judge Hafele, to retrieve apparently stolen emails containing confidential and attorney-client protected information about three sex abuse victims that have bee

a jury. 6 EFTA00804567 CERTIFICATE OF SERVICE Counsel hereby certify that a true copy of the foregoing was furnished by mail to The Honorable Donald W. Hafele, 205 N. Dixie Highway, Room 10.1216, West Palm Beach, FL 33401, and to all counsel on the attached service list, by email, on March 13, 3 018. B~I

y for Judge Hafele to enter a written order implementing his oral rulings. A further problem is that disputes have arisen about the scope of Judge Hafele's oral order. Epstein's counsel contend that they are entitled to make further copies of all the confidential materials for "appellate purposes." Th

ere was originally, my understanding is, two CDs that were delivered to Fowler White for printing. Those documents were then put onto one CD, with Bates numbers, and the documents were printed. So we now have a single CD, that's correct. THE COURT: And is the information contained on this disputed

the objection of the law firm, the electronic documents were to be turned over to Fowler White so that Fowler White could print out a hard copy of Bates stamped, numbered e-mails extracted from those multiple compact disks. This Court entered an order on November 30, 2010, recognizing the fact that

laim some of them are privileged. They submitted a privilege log, Mr. Scarola said it was for this Court. It wasn't. The privilege log is in Judge Hafele's court, in the 15th Judicial Circuit in Palm Beach County. OUELLETTE & NIAULDIN COURT REPORTERS, INC. EFTA00787735 1 2 3 4 5 6 7 8 9 1

2 of 23 Epstein or his legal counsel might misappropriate these documents while in their physical possession for the limited purpose of copying and Bates numbering them, this Court specifically ordered that "Fowler White will not retain any copies of the documents contained on the discs provided to i

ad represented a number of Epstein's victims in their civil suits against Epstein. Farmer Jaffe sought to have Epstein bear the costs of copying and Bates stamping these thousands of documents [DE 1120], ultimately resulting in an order from this Court that Epstein's counsel— attorneys at the law firm

er. Ultimately, following a summary judgment motion by Edwards, Epstein dropped his lawsuit; currently pending before Judge Crow's successor, Judge Hafele, is a follow-on action, Edwards v. Epstein, for malicious prosecution by Epstein in filing his lawsuit in the first place. 6 EFTA00799319 Case 0

to be done, and we've put that in a motion for order to show cause, is you copy the documents into a short term temp file, then you transpose the Bates number over those documents and burn the results onto the disk. That's the disk that we returned. We returned original disks to Judge Carney, we h

ponse to the motion for order to show cause, Fowler White was told, you will get the original CDs, and you will then print the documents after you Bates number them. The only way for that to be done, and we've put that in a motion for order to show cause, is you copy the documents into a short term

ending -- MR. LINK: The actual --- THE COURT: -- is Edwards versus Epstein for malicious prosecution? MR. LINK: Yes, sir, and that is set on Judge Hafele, the state court's trial docket -- December 4th or 10th? December 4th, specially set. THE COURT: So at the time the -- what was it, 26 boxes of doc

Exhibit List; continue working on Amended Exhibit List; work on Response to Motion for Sanctions; prepare Motion to Compel B. Edwards to identify Bates stamp numbers of documents produced June 12, 2018 Invoice # 797 Hours Amount 9.20 2,070.00 6.40 4,800.00 6.70 0.00 9.80 2,205.00 EFTA00

J. Epstein on deposition dates; communications with D. Indyke re strategies and purpose of case management conference; work on Motion to Compel re Bates documents 05/03/18 PVD [No Charge] Continue work on Amended Exhibit List cross referencing exhibits previously marked 05/03/18 KBR Prepare for

ghts and comments; update list of pending Motions; prepare Response to B. Edwards' Motion for Case Management; prepare letter and package to Judge Hafele re UMC hearing on case management; work on Response to B. Edwards' Motion for Sanctions to incorporate D. Indyke's suggested thoughts and comments

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

:16,19 6:17 40:25 43:11 goods 9:23 grant 9:18 31:22 granted 5:2 31:13 47:15,15 guidance 16:7 H Hafele 20:1,6 21:7.12 22:1723:11,16,18 24:1 Hafele's 19:24 21:8 22:14 hand 50:14 Hang 47:21 happen 37:3 happened 22:9 28:4 30:3 34:23 37:2 38:11,12 happy 16:20 hard 12:12 14:14 having 14:142

originally, my understanding 3 is, two CDs that were delivered to Fowler White for 4 printing. Those documents were then put onto one CD, with 5 Bates numbers, and the documents were printed. So we now 6 have a single CD, that's correct. 7 THE COURT: And is the information contained 8 on this d

of them are 22 privileged. They submitted a privilege log, Mr. Scarola 23 said it was for this Court. It wasn't. The privilege log 24 is in Judge Hafele's court, in the 15th Judicial Circuit 25 in Palm Beach County. Page 18 1 MR. LINK: Judge, if I can just respond 2 briefly on behalf of Mr. Epst

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

s and costs in his defense of those claims. In addition, when we identified several key case-ending e-mails from the disc as trial exhibits, Judge Hafele struck those exhibits as untimely. Furthermore, Judge Hafele did not want to make any rulings in derogation of the Bankruptcy Court's Order if Fowle