Epstein Secrets

d in response to -- as we've said in our response for -- motion for order to show cause, they had to put the documents on to a new disk to put the Bates numbers on them. So that's what was done. THE COURT: And so it was done after the discovery was completed -- MR. McLACHLAN: No. THE COURT: -- beca

r Fowler White. You'll remember what this case is about, Judge. There was discovery in late December. Fowler White printed the documents, had them Bates numbered pursuant to the agreement of the parties and this Court's order. About seven and a half years later Mr. Epstein's new counsel -- Fowler

25 Page 3 THE COURT: Good morning. Please be seated. Rothstein Rosenfeldt & Adler. MR. McLACHLAN: Good morning, your Honor. Niall McLachlan of Carlton Fields on behalf of Fowler White Burnett, P.A. MR. PUGATCH: Good morning, your Honor. Chad Pugatch, P-u-g-a-t-c-h, here as co-counsel on behalf of Jeffr

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

17 18 19 20 21 22 23 24 25 Page 3 THE COURT: Rothstein Rosenfeldt & Adler. MR. McLACHLAN: Good morning, your Honor. Niall McLachlan from Carlton Fields on behalf of Fowler White Barnett. MR. PUGATCH: Good morning, your Honor. Chad Pugatch, P-u-g-a-t-c-h, on behalf of Jeffrey Epstein. Co-counsel,

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

on Fields Jorden Burt, P.A. Miami Tower 100 S.E. Second Street, Suite 4200 Miami, FL 33131-2113 November 29, 2018 Via E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit C