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99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant's assertions regarding her relationship to each of th
on January 6, 2015, #1030-43. c. Jaffe on March 15, 2011, #1000-19.2 Gow on January 2, 2011, #1020-26. Gow and Basham on January 2, 2015, #1027- Barden #1059-83, Some emails were forwarded or carbon copied ("CC'd") later in the chain, leading to some overlap and duplication. Whether one party or
The Privilege Claims at Issue Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant
he hired Jaffe in 2009 to represent her in connection with a deposition. Maxwell Decl. 1 9. Though Defendant has failed to specify the end-date of Jaffe's representation, the in camera submissions demonstrate that these communications were made within the context of an ongoing attorney-client relati
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
bsflIp.com University of Utah 383 University Street Salt Lake City, UT 84112 Tel: 801-585-5202 Fax: 801-585-2750 [email protected] Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: 954-524-2820 Fax: 954-524-2822 brad@pathtoj
d, the media obtained copies of the motion. At issue is a January 2, 2015, statement prepared by Ms. Maxwell's British solicitor Philip Barden. Mr. Barden sent the statement to Ms. Maxwell for approval and, following approval, caused Mr. Gow to send (via email) the statement to six to thirty members of
Boulevard, Suite 1200 Ft. Lauderdale, FL 33301 Tel: Fax: University of Utah 383 University Street Salt Lake Cit , UT 84112 Tel: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 North Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301 Tel: Fax: 49 Twin Lakes Road South Salem, NY 10
Entities connected to both Barden and Jaffe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSON
Weissing
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
Paul Cassell
PERSONFISTOS & LEHRMAN
ORGANIZATION
Alan Dershowitz
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Virginia Giuffre
PERSONSouthern District
LOCATIONthe Southern District
LOCATION
Prince Andrew
PERSON
the University of Utah
ORGANIZATION
Alfredo Rodriguez
PERSON
Colorado
LOCATION