Epstein Secrets

l Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Philip M. Burlingt

Bankruptcy Movants claim that Fowler White's retention of the disc is a violation of the November 2010 Agreed Order and they seek sanctions against Fowler White and Epstein for that retention. A show cause hearing is currently scheduled before the Bankruptcy Court on August 23 and 24, 2018. The Bankr

P. Vitale, Jr. Florida Bar No.: 115179 Attorney E-Mails: [email protected]; and [email protected] Primary E-Mail: [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Attorneys for Bradley J. Edwards 4 EFTA00808123 Ca

ng Show Cause hearing because Edwards is entitled to cross- examine Epstein on the recent discovery that not only did the disc not "sit in a box" but Fowler White printed at least 32 pages of materials from the disc (26 of which are listed in Edwards' privilege log) and made handwritten notations on at

P. Vitale, Jr. Florida Bar No.: 115179 Attorney E-Mails: jsrasearcylaw.com; and [email protected] Primary E-Mail: [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards

in any copies of the documents contained on the discs provided to it, nor shall any images or copies of said documents be retained in the memory of Fowler White's copiers. Should it be determined that Fowler White or Epstein retained images or copies of the subject documents on its computer or otherw

laintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Philip M. Burlington

l ruling on March 8, 2018, incorrectly asserting that the Court prohibited Epstein from referring, in any way, to the 27,000+ pages contained on the Fowler White CD. His claim is that Epstein violated this Court's ruling the four times Epstein "referenced" the documents at issue in one filing with this

Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant1Counter-Plaintiff Bradley J. Edwards Philip M. Burlington

this Court's verbal ruling on March 8, 2018, asserting that Epstein was prohibited from referring, in any way, to the 27,000+ pages contained on the Fowler White CD. His claim is that Epstein violated this Court's ruling the four times Epstein "referenced" the documents at issue in one filing with this

Plaintiff/Counter-Defendant Jay Epstein 8 EFTA00808693 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Philip M. Burlington N

n of privilege has ever been made. In addition, the Bankruptcy Court has already issued an Order to show cause allowing discovery focused on whether Fowler White and/or Epstein violated the November 2010 Agreed Bankruptcy Order. Moreover, this Court has ruled that at this point, the 47 exhibits are not

, 2018. JAC• OLA ar No.: 169440 N E. TERRY rida Bar No.: 45780 AVID P. VITALE JR. Florida Bar No.: 115179 Attorney E-Mails: Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards 9 EF

aring, this Court entered a blanket confidentiality order prohibiting Epstein from using or referring to, in any way, the documents contained on the Fowler White CD: As a general blanket order I would simply say that all attorneys who have or are representing Mr. Epstein shall be subject to this order

gistered users on the CM/ECF system, which includes counsel identified on the service list below. SERVICE LIST Jack Scarola Sears Denn , Scarola, Barnhart & Shipley, P.A. yard Counsel for Bradley J. Edwards Paul G. Cassell S.J. Quinney College of Law at the University of Utah Counsel for LM., E.W. and Jane D

Epstein's co-counsel contacted Fowler White and inquired about any confidentiality orders concerning the CD, counsel was specifically told that the Fowler White attorney could not specifically remember due to the age of the file, but that he thought there was such an order and that Epstein's counsel sh

rida Bar No.: 169440 KAREN E. TERRY Florida Bar No.: 45780 DAVID P. VITALE JR. Florida Bar No.: 115179 Attorne E-Mail s : and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone Fax: Attorneys for Bradley J. Edwards EFTA00793951 COUNSEL LIST B

ation derived from the documents. The April 13, 2018 Bankruptcy Court Hearing 6. On April 13, 2018, a hearing was held before Judge Ray concerning Fowler White and Epstein's improper retention of the disc at issue, which Edwards contends is in violation of Judge Ray's Order dated November 30, 2011. A

Jeffrey Epstein Jack Scarola, Esq. Florida Bar No.: 169440 David P. Vitale, Jr., Esq. Florida Bar No.: 11517 Attorney E-Mails: Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach. Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards Niall T. McLachlan Carlton F

nation: "Perhaps I'm being a bit naive when I say that having served Mr. Epstein in their capacity as counsel, it's my respectful belief that they [Fowler White] owed an obligation to Mr. Epstein, if not this Court, to explain how and why they had access and kept these records in their possession in li