Epstein Secrets

l Jeffrey Epstein to Pay for the Production of All Documents in Response to His Request Filed by Interested Party Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. (hereinafter "Agreed Order Cancelling Hearing"). DE 1194. Movants request sanctions against Fowler White, a law firm which withdrew from repr

uous order must be made before the burden shifts to the alleged contemnor to produce evidence explaining his noncompliance at a show cause hearing. Burgess, 143 F.3d at 1436. "Clear and convincing evidence entails proof that a claim is 'highly probable,' a standard requiring more than a preponderance o

HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through counsel, hereby moves this honorable Court for an Order to Show Cause Why Fowler White and Jeffrey Epstein Should N

"[a] petitioner `must [first] establish by clear and convincing evidence that the alleged contemnor violated [a] court's earlier order." Chairs v. Burgess, 143 F.3d 1432. 1436 (11th Cir. 1998) (quoting United States v. Roberts, 858 F.2d 698. 700 (1 I th Cir. 1988)). Once such a prima facie showing of c

keted as of today's date, as timely filed. DATED: January 21, 2015. Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad(gpathtojus

11th Cir. 1999); United States , Pali!, supra, 338 F. d 1299 (11'h Cir. 2003); United States Garrett, 190 F.3 1220 (11th Cir. 1999); United States Burgess, 175 F.3d 261 (116 Cir. 1999); United States' Rojas, 145 Fed. Appx. 647 (11th Cir. 2005); United States' Root, 296 F.3d 1222 (11th Cir. 2002). Unit