Epstein Secrets

documents or data over which a claim of privilege was asserted by or on behalf of Rothstein Rosenfeldt Adler PA; Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards. MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which DRAFT !!!! NOT PROOFREAD EFTA00804

EAD EFTA00804173 13 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 declaration states that as part of Fowler White's representation of you, that they represented you in proceedings in the bankruptcy case concerning a subpoena that your original counsel issued to

hat would cover any claim that has or may result from Fowler White's retention of documents and/or a disc that (1) Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., (2) Bradley J. Edwards, and (3) L.M., E.W. and Jane Doe have alleged were improperly retained: a. The name of the insurer; b. The name of

ation with regard to each known policy of insurance, including excess or umbrella insurance, that would cover any claim that has or may result from Fowler White's retention of documents and/or a disc that (1) Farmer Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L., (2) Bradley J. Edwards, and (3) L.M., E.W. a

2820 EFTA00808125 Case 09-34791-RBR Doc 6487 Filed 10/22/18 Page 7 of 12 Fax: (954)-524-2822 Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Jay Howell Jay Howell & Associates Florida Bar No.: 225657 Attorney E-Mail(s): [email protected] 644 Cesery Blvd. #250 Jacksonville, FL 3

Order did not "sit in a box" for the past eight (8) years. This fact, however, was only uncovered at the October 19, 2018 deposition duces tecum of Fowler White's corporate representative, which was conducted after Epstein's deposition on October 13, 2018. Thus, the Court should not excuse Epstein from attend

y N. Henderson Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer Ja,ffe, Weissing, Edwards, Fistos & Lehrman, a Paul G. Cassell S.J. Quinney College of Law at the University of Utah 383 S. University Street Salt Lake City, UT 84112-0730 casse11p08aw.ut

ts on a disc, not sexual abuse claims. Simply, the Intervenors seek money damages for significant emotional distress because a disc sat in a box in Fowler White's files for eight years. Because the Intervenors appear to have failed to present this Court with requisite proof of their damages, this Court can eit

pley, P.A. Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC °tense or anner a e, ersstng, cards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Shapiro Law uite 3000 ounse or ., . . an

received select documents from the disc in February 2018. The select documents were provided to Epstein after Link & Rockenbach located the disc in Fowler White's boxes in February 2018. Because there are no material facts in dispute, live testimony will have no impact on this Court's determination of whether

nderson FLBN 118247 ION 1 EFTA00793676 Case 09-34791-RBR Doc 6496 Filed 10/25/18 Page 2 of 3 Attorneys for Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 25, 2018, I electronically filed the foregoing document with the Clerk of the Court

in its capacity as legal counsel to Jeffrey Epstein. Any violation that occurred with respect to Jeffrey Epstein individually is as a consequence of Fowler White's wrongdoing. The moving parties are therefore dropping the Motion for Contempt against Jeffrey Epstein in order to focus the attention where it is m

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

. Movants request sanctions against Fowler White, a law firm which withdrew from representing any party in this case nearly six years ago. DE 3034. Fowler White's investigation has not revealed how the offending CF ended up in its files since it sent the disk back to Special Master Carney after printing the do

, P.A. rd Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC ounse or armer a e, eissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of h Counsel for L.M., E.W. and Jane Doe Peter E. Shapiro Sha.iro Law Coun

received select documents from the disc in February 2018. The select documents were provided to Epstein after Link & Rockenbach located the disc in Fowler White's boxes in February 2018. Because there are no material facts in dispute, live testimony will have no impact on this Court's determination of whether

ccurred on October 13, 2018. Due to the impermissible questions, Epstein additionally moves this Court to require Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), Bradley J. Edwards ("Edwards") and Intervenor L.M. ("L.M.") (collectively, the "Movants") to pay Epstein's attorneys' fees

hat request. (D.E. 6325; D.E. 6345.) Movants allege that Fowler White EFTA00794256 and Epstein violated this Court's November 2010 Agreed Order by Fowler White's alleged retention of a copy of a disc that was provided to Epstein and his current counsel (Link & Rockenbach) in 2018. (D.E. 6326 at 6-11.) The No

unse or ra ey wars Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC e, Suite 2 301-3268 ounse or armer affe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Sha iro Law uite 3000 Counsel for L.M., E.W

received select documents from the disc in February 2018. The select documents were provided to Epstein after Link & Rockenbach located the disc in Fowler White's boxes in February 2018. Because there are no material facts in dispute, live testimony will have no impact on this Court's determination of whether