ounsel. Fanner Jaffe shall furnish copies of the segregated documents to which it asserts a privilege both to the Special Master and the Trustee at Farmer Jaffe's cost. d. To the extent that documents on the CD are duplicated and not subject to an assertion of privilege, they shall be forthwith provided to c

rs, which ended up with the order that we're talking about today. Another point of clarification, Mr. Scarola says that the order was entered over Farmer Jaffe's objection. He may have had some -- the law firm may have had some concerns, but it's very clear it's an agreed order. I don't know that that makes

have knowledge of the custody of the disk, but there was no reference to production of documents, as was specifically requested in Mr. Edwards or Farmer Jaffe's motion. In addition, Judge, we believe that the scope of what Mr. Edwards is seeking is almost ridiculously overbroad. His request, essentially,

s numbering of this large volume of documents be incurred by Jeffrey Epstein, as he was 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

proceedings, Fowler White disclosed that there were approximately 30 documents included in the file with the disc, some of which were contained on Farmer Jaffe's privilege log and contained handwriting from what appears to be a Fowler White employee. Mr. Edwards and Farmer Jaffe asserted that the disc was a d

ONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fowler White Burnett, P.A. ("Fowler White"), by and through undersigned counsel, hereby responds to Farmer Jaffe's Motion for Issuance of an Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to

granted motions from former Farmer Jaffe partner Bradley J. Edwards, who represented nine of Epstein's victims, and three of those victims to join Farmer Jaffe's sanctions 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 E

g 2.10 829.50 Motion to Strike Intervenors' List of Requested Relief 05/22/18 RJG In Bankruptcy Proceedings, review/analyze (1) 3.50 1,382.50 Farmer Jaffe's Motion for Order to Show Cause-Contempt; (2) Intervenors' Joinder in Motion for Order to Show Cause; (3) Court's Order to Show Cause-Contempt; and

onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried in order to interview jurors; research Farmer

there had been a waiver of any privilege with regard to documents contained on the disc that permitted you to file documents that were included on Farmer Jaffe's privilege log. Ianno (Fowler White's counsel): And I want to add my objection that that has nothing whatsoever to do with the motion, the order or

OSTS, AND FOR OTHER APPROPRIATE RELIEF Bradley J. Edwards, through counsel, hereby files this Reply to Jeffrey Epstein's Response in Opposition to Farmer Jaffe's Motion to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt of Court, to Permit Discovery, to Assess Sanctions and Cost

n this case on behalf of Epstein from the Gunster law firm. 7. Epstein will pay Fanner Jaffe reasonable attorneys' fees and expenses connected with Farmer Jaffe's efforts to determine the circumstances surrounding the retention and release of the materials and to undo any damage caused to Famer Jaffe or its cl

onse to S. Rothstein's 4.50 3,375.00 Motion to Dismiss; work on Objection to Duces Tecum in State Court action 06/25/18 TLC Work on Response to Farmer Jaffe's Summary of 6.20 1,395.00 Damages; work on trying to locate recent automobile case J. Scarola tried In order to interview jurors; research Farmer

Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Farmer Jaffe's Privilege Log. 23. On March 7, 2018, L.M. and two other minor girls Epstein had sexually abused, E.W. and Jane Doe, filed an emergency motion to i

edies as the Court may find just and proper. CONCLUSION The Court should grant the three Victims' the relief requested above, including joinder in Farmer Jaffe's motion for sanctions and their own sanctions and other relief, for reasons as described in DE 6345 and DE 6357, as well as Farmer Jaffe's related pl

tions filed in the Circuit Court. 14 EFTA00808717 C. Bankruptcy Court D.E. 6351 Date Document 04/09/18 Epstein's Response in Opposition to Farmer Jaffe's Motion for Issuance of an Order to Show Cause, etc. Page 2 "The Court should not spend its valuable time and resources on this transparent and fri

ry, Epstein did not file any answer or response, even though Epstein had previously filed a detailed Response in Opposition to Bradley Edwards' and Farmer Jaffe's Summaries of Damages for violation of the same order from this Court. See DE 6394. Accordingly, unlike the damages sought by Mr. Edwards which Epste