EFTA01199139Set 9
30p11,561w
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EFTA01199140
https://www.justice.gov/epstein/files/DataSet%209/EFTA01199139.pdf
EFTA00799314Set 9
2018-03-1923p6,803w
COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR
OTHER APPROPRIATE RELIEF
Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through
counsel, hereby moves this honorable Court ... Epstein served a broad subpoena
attempting to secure thousands of attorney communications by Fanner Jaffe attorney Bradley J.
Edwards, Esq., who while previously employed as an attorney at Rothstein Rosenfeldt ... Fowler White")—would make a copy
of the materials and return them to Fanner Jaffe. Because of Fanner Jaffe's obvious concern that
1
EFTA00799314
Case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799314.pdf
EFTA00808869Set 9
2018-04-0927p8,919w
Permit Discovery, to Assess Sanctions and Costs, and for Other Appropriate
Relief filed by Fanner, Jaffe, Weissing, Edwards & Fistos & Lehrman, P.L. ("Farmer Jaffe") (D.E.
6326) and the Joinder filed ... copy thereof, that is the subject of
their Motion. In fact, neither Fanner Jaffe nor Edwards make any such assertions against Epstein.
Instead, they level speculative allegations against Fowler White ... signed. Furthermore, while Link &
Rockenbach recognized that some of the documents were listed on Fanner Jaffe's privilege log,
as set forth above, the documents Link & Rockenbach
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808869.pdf
EFTA00802116Set 9
2018-10-2612p4,437w
other attorneys who had been employed at Rothstein Rosenfeldt
Adler, P.A ("RRA") later formed Fanner, Jaffe, Weissing, Edwards, Fistos & Lerhman, P.L.
("Fanner Jaffe"), where Edwards continued to litigate numerous cases ... unusable, Edwards Exhibit 7, and the
Trustee sent two replacement CDs to Fanner Jaffe on or about November 9, 2010. Edwards Exhibits
9-12. Edwards and L.M. subsequently filed ... Agreed Order refers to delivering printed copies of the Bates numbered documents to
Fanner Jaffe and Special Master Carney, pursuant to Judge Canvey's request, Ms. Sanchez sent the
originals
https://www.justice.gov/epstein/files/DataSet%209/EFTA00802116.pdf
EFTA00811395Set 9
2018-11-2112p4,431w
individually, and L.M.,
individually, Defendants, Case No. 502009CA040800XXXX MB AG (the "State Court Action").
(Fanner Jaffe Weissing Ex. I). The subpoena was issued by Jeffrey Epstein seeking documents to
support ... stamping as set forth in the Agreed Order, and that no one from the Fanner Jaffe
firm wished to be present during the process. (Fowler White Exhibit C; Declaration ... Agreed Order refers to delivering printed copies of the Bates numbered documents to Fanner Jaffe
and Special Master Carney, pursuant to Judge Camey's request, Ms. Sanchez sent the originals
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811395.pdf
EFTA00795972Set 9
2018-03-193p816w
within seven days of the entry of this order, to provide to counsel for Fanner Jaffe all
physical, electronic, and other information in their possession concerning the copying, retention ... Epstein (including all of Epstein's past and present legal counsel)
will provide to Fanner Jaffe within seven days of the entry of this order a listing of all persons ... Filed 03/19/18 Page 3 of 3
5. Counsel for Fanner Jaffe is permitted to depose those persons with knowledge of the
circumstances surrounding the copying, retention, or dissemination
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795972.pdf
EFTA01089004Set 9
37p28,789w
BRADLEY J. EDWARDS, ESQUIRE) 12 Q. And I will refer to it as Fanner, Jaffe,
13 having been first duly sworn or affirmed, was 13 if that's all right ... with you. Is Fanner, Jaffe
14 examined and testified as follows: 14 itself a P.A.; that is, are you a partnership of
15 THE WITNESS ... then your LLC is a partner of the
25 deposition taken before? 25 Fanner, Jaffe firm? 1
Page 6 Page 8
1 A. No. 1 A. Correct.
2 Q. Okay
https://www.justice.gov/epstein/files/DataSet%209/EFTA01089004.pdf
EFTA00806956Set 9
2017-11-0111p3,252w
received a copy of the
27,000+ pages when Fowler White provided copies to Fanner Jaffe and the Special Master in
2010, never had the CD, never knew that ... hold
him in statutory contempt or impose other sanctions under 11 U.S.C. § 105(a).
Fanner Jaffe, Edwards and the Intervenors bear the burden to demonstrate that Epstein
violated the Agreed ... show that there is nothing to coerce Epstein into compliance with, and
that neither Fanner Jaffe, Edwards nor the Intervenors are able to prove any actual damages
attributable to Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806956.pdf
EFTA00793762Set 9
2018-03-264p1,327w
March 19 motion that recent developments in ongoing litigation between Epstein and
former Fanner Jaffe partner Bradley J. Edwards, who represented several of Epstein's victims,
showed that Fowler White ... copied
EFTA00793762
and retained highly sensitive confidential and privileged materials for over seven years," Fanner Jaffe
said in its motion. "The misappropriation of this information has caused irreparable harm."
Farmer ... documents to this day remain in the
possession of the victims' sex abusers, Epstein," Fanner Jaffe said.
Epstein has also provided out-of-context and misleading summaries of the cmails
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793762.pdf
EFTA00622901Set 9
2013-05-154p637w
Copies of income tax returns for the past three (3) calendar years of Fanner,
Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.
4. Copies of all documentation related to all settlements, attorneys ... fees
awards, jury verdict awards, and arbitration/mediation income received by Fanner, Jaffe,
Weissing, Edwards, Fistos & Lehrman, P.L., and/or Bradley J. Edwards, PA.
5. Income tax records for the current ... copies of any estimated
income tax returns filed for the current year for Fanner, Jaffe, Weissing, Edwards, Fistos &
Lehrman, P.L.
6. A copy of Edwards's (or Bradley J. Edwards
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622901.pdf
EFTA00793668Set 9
2010-04-168p2,752w
image of our documents remains at [Fowler White]."
Special Master Carney took offense to Fanner Jaffe's insinuation that Jeffrey Epstein or any member
of his legal team might look ... documents from the February 23,
2011 privilege log be produced and Edwards and Fanner Jaffe complied. The remaining 6,308
pages of documents catalogued on the privilege log were never ... contained 32 printed, hard copy emails, 24 of which are currently listed on the Fanner Jaffe
privilege log and which were never produced. One email contains handwritten notations indicating
that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793668.pdf
EFTA00787704Set 9
2018-04-1313p10,979w
course, for eight years, and
16 says that the order was entered over Fanner Jaffe's 16 then all of a sudden when we turn over 36 bankers boxes ... there was a violation at some point when we received 10 Fanner Jaffe is claiming they've suffered damages, we
11 the disk back, there is no question there ... they say is they need discovery to 17 any time opened by someone at Fanner Jaffe's firm, that
18 determine the amount of their damages, which is kind
https://www.justice.gov/epstein/files/DataSet%209/EFTA00787704.pdf
Agreement") is made and entered
into this _ day of , 2011, by and between Fanner, Jaffe, Weissing, Edwards, Fistos,
& Lehrman ("Farmer Jaffe"), Fowler White & Burnett, P.A. ("Fowler"), and Searcy Denney
Scarola ... documents are being produced under this
paragraph.
2. With regard to the documents that Fanner Jaffe believes are irrelevant to any
issues in the Epstein v Rothstein, Edwards Litigation, Case ... determined to be irrelevant, the
documents will be returned by Fowler to Fanner Jaffe with no copies retained. If the objections
to production of documents on the basis of relevancy
https://www.justice.gov/epstein/files/DataSet%209/EFTA01101239.pdf
EFTA00795939Set 9
2010-11-306p1,416w
production from the RRA trustee of
approximately 27,000 emails to be delivered to Fanner Jaffe for the review and creation of a
privilege log. On November 30, 2010, this ... documents, and this Court retained jurisdiction to award sanctions on
behalf of Fanner Jaffe, Edwards, or clients in the event that it was determined that Epstein or
Fowler White retained ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00795939.pdf
EFTA01143024Set 9
2011-12-0924p4,729w
West Palm Beach, FL 33401
Phone: (561) 659-8300
Fax: (561) 835-8691
Fanner, Jaffe, Weissing, Edwards, Fistos &
Lehrman, PL
425 N. Andrews Avenue, Suite 2
Fort Lauderdale ... Suite 700
Attorneys for Jeffrey Epstein Fort Lauderdale, FL 33301
Phone: (954)-745-5849
Fanner, Jaffe, Weissing, Edwards, Fistos & Fax: (954)-745-3556
Lehrman, PL Attorneys for Scott Rothstein ... Suite 700
Attorneys for Jeffrey Epstein Fort Lauderdale, FL 33301
Phone: (954)-745-5849
Fanner, Jaffe, Weissing, Edwards, Fistos & Fax: (954)-745-3556
Lehrman, PL Attorneys for Scott Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01143024.pdf
EFTA00206606Set 9
2010-09-023p520w
Motion for Protec
ter, Jaffe") (D.E. #818) and
Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Pain
ent of all counsel present at the
its related amendment ... counsel for the Trustee to hear their respective
counsel for Epstein, counsel for Fanner, Jaffe and
the review by the Special Master, the
positions concerning these matters. Upon completion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206606.pdf
EFTA00213899Set 9
2010-09-023p520w
Motion for Protec
ter, Jaffe") (D.E. #818) and
Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Pain
ent of all counsel present at the
its related amendment ... counsel for the Trustee to hear their respective
counsel for Epstein, counsel for Fanner, Jaffe and
the review by the Special Master, the
positions concerning these matters. Upon completion
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213899.pdf