EFTA00722554Set 9
2006-12-0510p3,003w
confidentiality letters between the S and DBZ, we are voluntarily producing a
Bates-stamped version of the binder of d• son,
presentation to the Staff on December I, 2 (Bates ... used in connecti rbson, Dunn & Crutcher presentation to the
Staff on January 9, 2007 (Bates-stamped D Z 0008373 - DBZ 0008536).
If you have any questions or concerns wi regar ... materials provided to the Staff during the
course of its investigation, including this letter (Bates-stamped DBZ 0008537 - DBZ 0008538),
Confidential Treatment Requested
by Fried Frank Harris Shriver & Jacobson
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722554.pdf
EFTA00793668Set 9
2010-04-168p2,752w
then determined that the number of documents that would need to be printed and Bates
stamped exceeded 27,000, which would have resulted in significant costs to the Farmer Jaffe ... 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 ... that awaits, we will take the unprecedented step of allowing an
opponent to copy & Bates stamp our and our clients' potentially privileged materials and give the
printed materials
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793668.pdf
EFTA00799314Set 9
2018-03-1923p6,803w
against Epstein. Farmer
Jaffe sought to have Epstein bear the costs of copying and Bates stamping these thousands of
documents [DE 1120], ultimately resulting in an order from this Court ... Brad Edwards or his client." [DE
1194).
12. On December 13, 2010, 27,542 bates stamped documents were provided to Farmer
Jaffe.
13. On January 25, 2011, Farmer Jaffe provided ... Fowler
White to take very limited possession of the subject documents to print and Bates stamp them, and
then not to retain any copies. This was also a short five
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799314.pdf
EFTA01069623Set 9
2012-05-085p1,211w
deposition
exhibits is timely made on all other parties directly. All exhibits shall be bate stamped in accordance
with the Schedule of Bate Stamp Designations attached to this order. Each ... exhibits shall be
produced in a separate brown expandable folder(s) in bate stamp numeric order, with a printed label
on the front of each folder which, in large font ... intended to be used at the deposition, they
shall be marked as the last bate stamped documents in their sequence. Any impeachment documents
shall be served upon Rothstein's attorney
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069623.pdf
EFTA00015219Set 8
2020-05-2658p17,292w
this declaration, could identify the actual exempt information protected by the FBI.
The FBI Bates-stamped all pages that it processed prior to July 2019 consecutively as "03956-1
through ... These records are referred to in this declaration collectively as the
Bates-stamped or Bates-numbered records.' I On the pages released in full or in part, these
" In contrast ... records processed after July 2019 were not Bates-stamped, as those records were
subject to categorical withholding per Exemption 7(A). Thus, when I refer to the Bates-
numbered records
https://www.justice.gov/epstein/files/DataSet%208/EFTA00015219.pdf
EFTA01069703Set 9
12p3,230w
disk so at our expense we
16 copied the documents, all had them bates stamped, we did
17 not keep copies, we turned them over to the special
18 master ... JUDGE CROW: Let me back up. The documents,
23 he's got a bates stamp on all of these so you have
24 received the documents which are any documents ... JUDGE CROW: I understand that. But the
7 ones that are not bates stamped, like he's got 01018
8 objection, and then the next one is 01080, so there
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069703.pdf
EFTA01077565Set 9
2011-03-15117p29,114w
SPECIAL MASTER CARNEY: Just so we're clear.
22 Actually, in terms of the Bates Stamp documents,
23 I still don't have the Bates Stamp documents ... never had the Bates Stamp documents.
25 MR. SCAROLA: They are available. They are
United Reporting, Inc.
(954) 525- 2221
EFTA01077610
Page 47
1 available. We've offered them before ... where we have a Master who now has or will
20 have all the Bates Stamp documents.
21 It seems to me at least determining
https://www.justice.gov/epstein/files/DataSet%209/EFTA01077565.pdf
EFTA00621488Set 9
2011-03-15117p29,066w
SPECIAL MASTER CARNEY: Just so we're clear.
22 Actually, in terms of the Bates Stamp documents,
23 I still don't have the Bates Stamp documents ... never had the Bates Stamp documents.
25 MR. SCAROLA: They are available. They are
United Reporting, Inc.
(954) 525- 2221
EFTA00621533
Page 47
1 available. We've offered them before ... where we have a Master who now has or will
20 have all the Bates Stamp documents.
21 It seems to me at least determining
https://www.justice.gov/epstein/files/DataSet%209/EFTA00621488.pdf
EFTA00802097Set 9
2018-10-267p1,935w
Edwards and Fanner Jaffe privilege log, that Fowler White was responsible
1
EFTA00802097
for Bates stamping and printing under the terms of the Agreed Order for the sole purpose ... that point a third, blank CD was installed and the Bates
stamped documents were burned to that CD. [48:21-25; 49:1]. Forensic review of the third CD
revealed ... that the Bates stamping process occurred on December 8, 2010, as the application of
Bates numbers constituted a "modification" to the CD. [32:14-21]. One hard copy of these
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802097.pdf
EFTA00793920Set 9
2018-04-1127p8,166w
04/11/18 Page 3 of 17
• The Fowler Jaffe firm agreed that Fowler White would bates stamp and print the
documents, then return the printed documents to Farmer Jaffe for preparation ... Trustee's CD
of documents, and that copy service shall duplicate and bate stamp all documents
on the CD, and return all materials to Farmer Jaffe, who shall forthwith notify ... Trustee's counsel and the Special Master of the bate stamp range of documents.
DE 1068,911(a), (c) (emphasis provided).
In stark contrast, the Agreed Order Cancelling Hearing does
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793920.pdf
EFTA01069308Set 9
2010-04-1686p14,016w
Edwards filed another Motion asking Jeffrey
Epstein to pay the costs of bate-stamping and production of the records needed for
the preparation of the privilege ... Agreed Order was entered on
November 30, 2010 whereby Fowler White would bate-stamp and copy the
records needed to be copied from the privilege log which initially was represented ... Trustee's CD of
documents, and that copy service shall duplicate and bate stamp all documents on the CD, and
return all materials to Farmer Jaffe, who shall forthwith notify
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069308.pdf