Epstein Secrets

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

rs, which ended up with the order that we're talking about today. Another point of clarification, Mr. Scarola says that the order was entered over Farmer Jaffe's objection. He may have had some -- the law firm may have had some concerns, but it's very clear it's an agreed order. I don't know that that makes

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

have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,

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

g 2.10 829.50 Motion to Strike Intervenors' List of Requested Relief 05/22/18 RJG In Bankruptcy Proceedings, review/analyze (1) 3.50 1,382.50 Farmer Jaffe's Motion for Order to Show Cause-Contempt; (2) Intervenors' Joinder in Motion for Order to Show Cause; (3) Court's Order to Show Cause-Contempt; and

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

Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffe's Privilege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to i

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

s numbering of this large volume of documents be incurred by Jeffrey Epstein, as he was no longer voluntarily willing to pay for the service. While Farmer Jaffe's motion was pending, Special Master Carney contacted Farmer Jaffe about Fowler White's offer to copy and Bates stamp the documents in-house to save

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

proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d

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

ONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fowler White Burnett, P.A. ("Fowler White"), by and through undersigned counsel, hereby responds to Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to

us concerns associated with 1 EFTA00795927 Case 09-34791-RBR Doc 6358 Filed 04/12/18 Page 2 of 12 allowing Epstein's lawyers to photocopy and Bates stamp the emails. There can be no doubt that Mr. Epstein explicitly violated this Court's clearly worded November 30, 2010 Order [DE 1194], a fact

OSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess Sanctions and Cost

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

n this case on behalf of Epstein from the Gunster law firm. 7. Epstein will pay Fanner Jaffe reasonable attorneys' fees and expenses connected with Farmer Jaffe's efforts to determine the circumstances surrounding the retention and release of the materials and to undo any damage caused to Famer Jaffe or its cl