Epstein Secrets

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

with jurisdiction over all discovery sought from the RRA Trustee. 6. On August 13, 2010, this Court appointed former Broward County Circuit Judge Robert Carney as Special Master, who was directed to work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by J

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

mer, of November 4, 2010? A I don't recall having seen this. No. Q The next email in this composite is an email of November 9, 2010, first from Robert Carney to Luis Torres, with a copy to Lilly Ann Sanchez. Have you seen that email before? A Yes, I have. 2010, from Seth Lehrman to Palm Beach Reporti

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

ct privileged 1 EFTA00793668 information. By Order dated August 13, 2010 [DE 888] this Court ordered the documents be produced to Special Master Robert Carney for the purposes of the Special Master preparing a privilege log, and that all legal fees and costs incurred by the Special Master be paid by Epstei

t of the parties as follows. The law firm of Fowler White Burnett, P.A., 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

at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Fanner Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and which contains all electronically stored information ("ESI") and other documents in the Trustee's possession, respecting the

ounsel) shall also provide all correspondence and billing records related to the copying, retention, and dissemination of the subject documents, the Bates stamping of the subject documents, or any other activity related to the November 30, 2011 Order from the day that the Epstein subpoena was issued o

and resulting dissemination of the subject privileged materials. Such inquiry should include, but not be limited to, testimony from Special Master Robert Carney, Jeffrey Epstein, Fowler White Attorney Joseph L. Ackerman, Fowler White Attorney Lilly Ann Sanchez, Jack Goldberger, Tina Campbell, Scott Link, Ka