Case File
efta-efta00793919DOJ Data Set 9OtherDS9 Document EFTA00793919
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DOJ Data Set 9
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I
M R
CIVIL TRIAL & APPELLATE LAW
LINK&
ROCKENBACH, PA
March 9, 2018
VIA ELECTRONIC MAIL
James N. Hurley
Fowler White Burnett
Brickell Arch, 14th Floor
1395 Brickell Avenue
Miami, FL 33131
jhurley®fowler-white.com
1555 Palm Beach Lakes Blvd., Suite 301
West Palm Beach, FL 33401
TEL
RE:
Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards
15th Judicial Circuit Case No. 50-2009CA040800XXXXMBAG
Dear Jim:
Yesterday, the Court ruled to exclude critical evidence on a disc containing 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 week. The
documents that we located on the disc demonstrate with clarity that Mr. Edwards' claims against Mr.
Epstein have no merit. Without being able to use these exhibits, our defense is severely prejudiced. We
are considering a Motion for Reconsideration but need Fowler White to take the lead on demonstrating
how it 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, by whom. The Court directed us to retain Fowler White's original boxes until this matter is
resolved. You are more than welcome, however, to review them at our offices if you need to reconstruct
what happened.
For your reference, I am attaching the transcript of the morning session of yesterday's hearing.
Also attached is a copy of Judge Ray's Order. The nilings relating to the disc and our retention were
made during the afternoon session and we are currently waiting for that portion to be transcribed. We
will provide it to you upon our receipt.
I look forward to hearing from you on this matter.
Sincerely,
Scott J. Link
SJL/tic
Enclosure
EFTA00793919
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10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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