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

I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR

mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1

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

I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR

mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1

as 1 through 182. We have an additional set of documents that are 183 through 215, that I do not believe are responsive to your notice. They are Bates-numbered emails. I don't know if you want to have these produced and made available to everyone or not. MR. SCAROLA: Are those the documents that

ing to Farmer Jaffe. Q And when you talk about a copy, are you talking about a hard copy? A A hard copy of the contents of the disc after being Bates stamped. Q Why were the discs delivered to the Miami office? A We had the facilities in the Miami office to do this job. Q What happened to t

we are not going to get into the general procedures of Fowler White on how they file things. BY MR. SCAROLA: Q Other than making Mr. Knight, Mr. Ackerman and Ms. Sanchez aware of the provisions of this order, did Fowler White do anything else at all in order to assure that the provisions of the orde

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

00, or whatever that number is — it escapes me because of its shear mass — is impossible and is not going to be countenanced here. (50:15-22.) Mr. Ackerman, Fowler White, had these materials ever since day one. I don't know how much more I can make this clear. (56:22-25.) That's the point that I'm tryi