hat Edwards claims are privileged and are currently under seal may be unsealed at the mediation and shown by Epstein's attorneys to the mediator and Fowler White's attorneys. Edwards' counsel shall bring Edwards' copy of the 47 e-mails to the mediation for this limited purpose. 8. The use of the 47 e-mails d

Jaffe who have the full authority to settle without further consultation shall appear at the mediation in person. Furthermore, a representative of Fowler White's insurance carrier who has full authority to settle in an amount up to its policy limits without further consultation shall appear at the mediation i

t Fowler White was unaware, as of the time that it came into possession of the discs delivered in response to the subpoena that had been issued at Fowler White's request, that Fowler White had an obligation to protect against any access to privileged or potentially privileged information on that disc; is th

eipt on the 8th. Q To whom were they directed in the Miami office? A I believe they were sent to Ms. Sanchez, but I'm not positive. Q What is Fowler White's understanding as to Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803650 20 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1

s no longer voluntarily willing to pay for the service. While Farmer Jaffe's motion was pending, Special Master Carney contacted Farmer Jaffe about Fowler White's offer to copy and Bates stamp the documents in-house to save Epstein costs. Special Master Camey recommended that Fowler White's offer be accepted

a clear review of documents that Fowler White knew it was not permitted to have in its possession. Perhaps more compelling, Mr. Hurley's review of Fowler White's internal records indicated that in 2014, Fowler White created an inventory of the items in its possession relating to Jeffrey Epstein when Fowler W

obtained the disc, why it had the disc, if it reviewed the emails on the disc, etc. Please let me know as soon as possible if through the review of Fowler White's billing records, you are able to reconstruct and identify how the disc was received, if the emails on the disc were reviewed by anyone and if so, b

g 27,500 pages of e- mails that Bradley Edwards has alleged were "stolen" in violation of Judge Ray's order. As you know, we obtained that disc from Fowler White's case files. Because these documents were in Fowler White's possession for many years, Judge Hafele has excluded us from using them at trial next wee

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

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

FTA00787726 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 Pagell the single CD that was supposedly in Fowler White's files, that's correct. There was originally, my understanding is, two CDs that were delivered to Fowler White for printing. Those documents were t

ft. Tr. 62:2-63:1.) 4. At the March 8, 2018, hearing, the Court also stated that the copy of the disc entitled "Epstein Bates Stamp" obtained from Fowler White's files should be filed under seal: ... that the one disk containing the documents that are being sought to be introduced at trial to take [sic] to r

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 otherwise, the

writing on behalf of my client, Jeffrey Epstein, in response to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's representation of him in the above-referenced matters during the period of June 2010 through May 2012. We are hopeful to put this matter to rest on

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

. 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

20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is permitted to depose Epstein in Palm Beach County concerning Epstein's knowledge of Fowler White's retention of the disc at issue. This line of inquiry includes whether Epstein had possession of the disc at any point prior to February 2018, when

s case is about to begin that they are le have been able to piece together, i0 very clearly Is first reviewing 36 boxes, or over 30 bozos of IS Fowler White's irproper retention of this na aaaaaa 14 files. Hight have bean 32. I think 36 is the 16 after they had been expressly ordered by the 17 ntabor.

bid. He also ordered them to file a summary of their alleged damages with the court. The judge also decided during the hearing to order Epstein and Fowler White's corporate representative to sit for depositions on the limited scope of how Epstein and his current counsel came to possess a compact disc allegedl

cution case, Farmer Jaffe asserts. On March 7, Epstein's current counsel gave Edwards' counsel a flash drive its said duplicated a disc it found in Fowler White's files and provided a sworn affidavit from a paralegal saying she had obtained the materials from Fowler White's files. According to the motion, dur

ein and D. Indyke re same; work on objection to duces tecum; work on Response to S. Rothstein's Motion to Dismiss; communications with J. lanno re Fowler White's insurance information 06/19/18 RJG Review Notice and Re-Notice of taking Video 1.90 750.50 Deposition Duces Tecum of J. Epstein, Bankruptcy Cou

ns against Epstein, he will seek recovery from Fowler White because Fowler White retained a copy of the disc without his knowledge. Second, but for Fowler White's actions in retaining the disc, the show cause proceedings would never have been brought against Epstein. Epstein has expended substantial attorneys'

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

name is M-c-L-a-c-h-1-a-n. I omitted that earlier. Judge, we have several matters on the calendar this morning. We have the continued hearing on Fowler White's motion for protective order, that's Docket Entry 6421. You may recall we had a hearing earlier, and the Court indicated that it would give, it wou