EMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS AND FOR OTHER APPROPRIATE RELIEF Farmer Jaffe Weissing Edwards Fistos & Lehrman ("Farmer Jaffe"), through counsel, hereby files this Summary of Damages in Support of Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Sho

7,000 emails and the creation of a privilege log, which has been rendered meaningless due to the violation; this task required the time of numerous Farmer Jaffe employees and in total well over 100 hours of time. Fanner Jaffe seeks reimbursement for only a fraction of that time: 40 hours of attorney time at

r Jaffe Weissing Edwards Fistos and Lehrman (“Farmer Jaffe”). I was thus with RRA for less than one year. In July 2010, along with other attomeys at Farmer Jaffe and Professor Cassell, I reached favorable settlement terms for my three clients Jj. WW... and Jane Doe in their lawsuits against Epstein. On July 2

ldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before

ldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before

ldt & Adler, P.A. ("RRA"). Some of the lawsuits were transferred to a newly formed firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL ("Farmer Jaffe"). Epstein has alleged and believes that the Defendants and perhaps other former employees of RRA conspired to use the Epstein/LM litigation before

:08-cv-80736-KAM Document 335 Entered on FLSD Docket 07/24/2015 Page 4 of 4 CASE NO: 08-80736-CIV-MARRAMATTHEWMAN SERVICE LIST Brad Edwards, Esc' Farmer Jaffe, Et Al. 425 N. Andrews Avenue Suite 2 Ft. Lauder - 268 Telephone: Facsimile: Attorneys for Jane Doe #1 and Jane Doe #2 Paul G. Cassell, Esq.

ollowing results. The subject was followed to a law office of Michael Levin which he stayed for about 30 minutes. Then he drove to the law office of Farmer Jaffe and stayed for about 90 minutes. On Tuesday April 27, 2010 The investigator conducted surveillance from 715am to 730pm, with the following results.

that the special master would review the actual documents. So reading the transcript, I believe the procedure Your Honor contemplated was that the Farmer Jaffe firm would have input before any of these documents were OUELLETTE & MAULDIN COURT REPORTERS, INC. (305) 358-8875 EFTA00731404 1 2 3 4 5 6

rivileged materials for over seven years," Fanner Jaffe said in its motion. "The misappropriation of this information has caused irreparable harm." Farmer Jaffe filed its motion in bankruptcy court in Fort Lauderdale, Florida, in the liquidation case of law firm Rothstein Rosenfeldt Adler PA, where Edwards h

EFTA00793957 Case 09-34791-RBR Doc 6366 Filed 04/20/18 Page 2 of 8 I. ALLEGATIONS Farmer, Jaffe, Weissing, Edwards, Fixtos & Lehrman, P.L. ("Farmer Jaffe") filed the Motion for Order to Show Cause [D.E. 6326] alleging that the attorneys at the law firm of Fowler White Burnett, P.A. ("Fowler White") v

Jaffe Weissing Edwards Fistos & Lehrman PL had said in a March 19 motion that recent developments in ongoing litigation between Epstein and former Farmer Jaffe partner Bradley J. Edwards, who represented several of Epstein's victims, showed that Fowler White retained a copy of confidential documents and th

MO had ovary rea➢on to 10 12 1 Jaffe, Miming, Edwards, Flacon and Lehrman• -- I believe that this respected is.. firm and these 2 THE COURT: Farmer Jaffe, right? 2 respected lawyers would do exactly what they were 3 MR. SCAROLA: Yes. Pinner Jaffe. 3 told to do. 4 THE COURT: Be can just refer co

MO had ovary rea➢on to 10 12 1 Jaffe, Miming, Edwards, Flacon and Lehrman• -- I believe that this respected is.. firm and these 2 THE COURT: Farmer Jaffe, right? 2 respected lawyers would do exactly what they were 3 MR. SCAROLA: Yes. Pinner Jaffe. 3 told to do. 4 THE COURT: Be can just refer co

. EFTA00794246 There are no disputed facts material to this show cause proceeding regarding Epstein. The Movants in these show cause proceedings (Farmer Jaffe, Bradley J. Edwards and L.M.) have acknowledged that Epstein did not have the disc or even know of the disc's existence before being advised by Lin

dwards"), (2) Jeffrey Epstein ("Epstein"), nors Jane Doe, M t and= (collectively, "Intervenors"), and (4) F' eissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Me cipants"), to participate in mediation subject to this Agreed Mediation Confidenti The Court, hereby ORDERS AND ADJU fo

esponses and Objections to the Notices of Taking Video Deposition Duces Tecum of Epstein [DE 6388]. Apparently, their position is that Edwards (and Farmer Jaffe and the Intervenors) are limited to deposition testimony only and have no ability to test the credibility of that sworn testimony through impeachmen

ive an opportunity to take discovery (in the form of interrogatories, requests for admission and production, as well as depositions as requested by Farmer Jaffe) on this important subject. 3. A DIRECTION THAT EPSTEIN WRITE A LETTER OF APOLOGY IS APPROPRIATE. The Victims have also requested that Epstein (a

and its insurer, (4) Intervenors Jane Doe, L.M. and E.W. (collectively, "Intervenors"), and (5) Farmer Jaffe Weissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Mediation Participants"), to participate in mediation subject to this Agreed Mediation Confidentiality Order. The Court, here

g 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. and Jane Doe have alleged were improperly retained: a. The

and its insurer, (4) Intervenors Jane Doe, L.M. and E.W. (collectively, "Intervenors"), and (5) Farmer Jaffe Weissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Mediation Participants"), to participate in mediation subject to this Agreed Mediation Confidentiality Order. The Court, here