proceedings is a disc labeled Epstein Bate Stamp that Fowler White had in its files and turned over in February to Epsteins current trial counsel Link Rockenbach The Bankruptcy Movants claim that Fowler Whites retention of the disc is a violation of the November Agreed Order and they seek sanctions against Fowler White and Epstein for that retention A show cause hearing is currently scheduled before the Bankruptcy Court on August and however Edwards has moved to continue it to September The Bankruptcy Court has allowed limited depositions of Epstein and representatives of Link Rockenbach and Fowler White Those depositions are currently set on August and respectively This Court also allowed the deposition of Epstein on an additional limited basis which is set on August Because the disc itself and the exhibits Edwards claims are privileged have been sealed by this Court Epstein respectfully moves to unseal those documents for the limited purpose of the Bankruptcy Courts show cause proceedings and the upcoming depositions BACKGROUND During the March hearing the Court instructed Epstein to file under seal Link Rockenbachs copy of the disc and exhibits identified on Epsteins March Clerks Trial Exhibit List which Edwards claimed were privileged The exhibits were filed under seal to protect Epsteins appellate rights The sealing was accomplished by the Courts April Agreed Order Directing Clerk to Seal Filings Exhibit A As outlined in Epsteins Notices of Compliance with the Courts March rulings Composite Exhibit Link Rockenbach maintains in a sealed box in its offices the unredacted Appendix served in support of Epsteins Response in Opposition to Edwards Second There was some delay in the sealing because the case was stayed pending appeal Supplement to Motion in Limine Addressing Scope of Admissible Evidence and a set of the e-mail exhibits Epsteins counsel printed from the disc and identified on Epsteins March Clerks Trial Exhibit List which Edwards claims were late disclosed and/or identified on his privilege log In addition Link Rockenbach has maintained in a sealed envelope with Fowler Whites original boxes the original disc that was located in Fowler Whites files ARGUMENT The Bankruptcy Courts Show Cause hearing is an evidentiary hearing and the parties are required to submit exhibits to the Bankruptcy Court two days in advance of the hearing The disc located in Fowler Whites records and the exhibits Epstein identified which were obtained from the disc and Edwards claims are privileged are the central focus of the hearing Similarly the witnesses testimony will be based on the disc and exhibits Epstein asks the Court to allow his counsel to unseal the box and envelope maintained in Link Rockenbach offices for use solely during the Bankruptcy Court ordered depositions when Edwards counsel is present The box and envelope will then be resealed at the conclusion of each deposition Epstein further requests that he be allowed to provide the Bankruptcy Court two days in advance of the show cause hearing with copies of the disc and exhibits and that his counsel be allowed to unseal the box and envelope for the duration of the show cause evidentiary hearing CONCLUSION Accordingly Epstein seeks permission from the Court to allow his counsel Link Rockenbach to unseal the box and envelope maintained in its offices for use as evidence at the Bankruptcy Courts show cause proceedings and as exhibits at the upcoming depositions as outlined above The exhibits include both the exhibits Edwards claims are privileged and other documents printed from the disc but which were earlier produced in the case CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on August through the Courts e-filingportal pursuant to Florida Rule of Judicial Administration Jack Scarola Karen Terry David Vitale Jr LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Philip Burlington Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com Co-Counsel for Defendant/Counter-Plaintiff Counsel for Defendant Scott Rothstein Bradley Edwards Jack A Goldberger Paul Cassell Atterbury Goldberger Weiss P.A University Australian A venue Suite Salt Lake City UT West Palm Beach FL cassellp law utah edu goldberger agwpa.com Limited Intervenor Co-Counsel for L.M E.W smahoney agwpa.com and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe EXHIBIT A JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and LM individually Defendants/Counter-Plaintiff IN TI-IE CIRCUIT COURT OF THE FIFTEENTHJUDICIALCIRCUIT IN AND FORPALM BEACH COUNTY FLORIDA Case No AGREED ORDER DIRECTING CLERK TO SEALFILINGS THIS MATTER coming before the Court upon Plaintiff/Counter.;.Defendant Jeffrey Epsteins CEpstein Motion to Make Court Records Confidential The Court pursuant to its ruling at the March hearing and bein,g advised of the agreement of the parties,it is hereby ORDERED AND ADJUDGED that the Motion is GRANTED The followingfofoririation is provided pursuant to Florida Rule of Judicial Administration and th JudiciaLCircuit Administrative Order A Type of Case Civil Grounds under subdivision for termining theinformation confidential The Court deems the items to be filed under seal confidential pursuant.to Florida Rule of Judicial Administration because Edwards Edwards and Intervenors L.M.,RW and Jane Doe Interveriors have asserted a.claim ofprivilege over the documents Jeffi Epsteinv Scott Rothstein etal th Judicial Circuit Case No Agreed Order Directing Clerk to Seal_Filings Page Whether any partys name is determined to be confidential and if so the particular pseudonym or other terms to be substituted for a party rianie The Couitis sealing the items listed below iri their enth 267ety Should any documents later be unsealed 267the documents win be redacted and pseudonyms andinitials will be used for Intervenors Jane Doe ahd L.M and any other persons the Court deems appropriate Whether any progress docket 9r similar records generated to document activity in the case are determined to be confidential No The particular information thaf is determined to be confidential Disclabeled Epstein Bates Stamp and The following clocuments Epstein identified on his March Clerks Trial Exhibit List the gray of which Edwards and the Intervenors have claimed as privileged Ex No Bates No App No i3;i __ I 1r Jefji Epstein Scott Rothstein et al th Judicial Circuit Case No Agreed Order Directing Clerk to Seal Filings Page3 Ex No Bates No biooil App No I so Jeffrey Epstein Scott Rothstein et al I th Judicial Circuit Case No Agreed OrderDirecting Clerk to Seal Filings rage Ex No Bates No Legamaro Depo Ex Legamaro Production idi App No Jeffi-ey Epstein Scott Rothstein etaL th Judicial Cfrc:uitCase No Agreed OrderDirecting Clerkto Seal Filings Page Ex No Bates No iiI I App No Identificaiion of persons who are permitted to view the confidential information Unless and until ordered by this Court only this Court and the Fourth District Court of Appeal shall be able to view the items under seal The Court finds that i the degree duration and mannenff confidentiality ordered by the Court are no broader than neces ary to protect the interests set forth in Florida Rule of Judicial Administration2.420_ arid ii less restrictive measures are available.fo protect.the interests set forth in subdivision The Clerk of Court is directed to publish the order in accordance with Florida Rule of JudiciaLAd1ihistration The items identified above shall remainurider 267seal until further orderofthis Court DONE AND ORDERED in WestPalm Beach Palm Beach un Florida this day of April DW HAFELE Jeffrey Epstein ScottRothstein el al th Judicial Circuit Case No Agreed Order Directing Clerk to Seal Filings Page SERVICE LIST Jack Scarola Philip Burlington Karen Terry Nichole Segal David Vitale Jr Burlington Rockenbach P.A Searcy Denny Scarola Barnhart Shipley P.A Courthouse.Commons Suite Palm Beach Lakes Boulevard West Railroad Avenue West Palm Beach FL West Palm Beach FL mep searcvlaw.com nmb FLAm ellateLaw.com jsx searcylaw.com njs FLA1meilateLaw.com dvitale searcylaw.com kbt FLA1:mellateLaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plainti.ff terrvteam searcvlaw.com Bradley Edwards Co-Counsel for Defendant/Cozmier-Plainti.ff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL I brad epllc.com marc nuriklaw.com Co-Counsel for Defendant/Counter-Plainti.ff Counselfor Defenda1it Scott Rothstein Bradley Edwards Jack A Goldberger Paul Cassell AUerbury Goldberger Weiss P.A University Australian A venue Suite Salt Lake City UT West Palm Beach FL cassellp law.utah.edu goldberner agwpa.com Limited Intervenor Co-Counsel for L.M E.W smahoney agwpa.com and Jane Doe Co-Counsel for Plainti.fJ/Counter-Defendant Jefjrey Epstein Jeffrey Epstein Scott Rothstein et al th Judicial Circuit Case No Agreed Order Directing Clerk to Seal Filings Page7 Scott Link Kara Berard Rockenbach Rachel Glasser Link Rockenbach PA Palm Beach Lakes Blvd Suite West Palm Beach FL Scott linkrocklaw.com Kara linkrocklaw.com Rachel linkrocklaw.com Tina linkrocklaw.com Troy linkrocklmv.com Trial Counsel for Plaintif7Counter-Defendant Jejji Epstein Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL javhowell.com Limited Intervenor Co-Counsel for L1 t1 E.W and Jane Doe EXHIBIT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff PLAINTIFF/COUNTER-DEFENDANT NOTICE OF SERVICE OF COURTS MARCH HEARING TRANSCRIPTS AND COMPLIANCE WITH COURTS RULINGS1 Plaintiff/Counter-Defendant Jeffrey Epstein Epstein hereby serves the transcripts morning and afternoon sessions of the March hearing and provides his Notice of Compliance with the Courts rulings Epstein will file this Notice with the Court once the stay is lifted THE COURTS RULINGS At that hearing the Court made the following rulings As to lntervenors E.W L.M and Jane Doe request to temporarily seal the pleadings relating to the e-mails the Court granted the request and asked for a proposed Order Morning Session The sanitized redacted version of Epsteins Notice of Filing Appendix shall be filed under seal Afternoon Session Although no written Order has been entered and the proceeding is stayed Epstein has complied with and will continue to comply with the Courts rulings on the record In order for Epstein to preserve his rights concerning the Courts rejection of the last-minute request for an in-camera inspection and the striking of his newly disclosed exhibits Epstein shall file under seal the newly disclosed trial exhibits which Edwards has claimed are privileged Afternoon Session These do not include exhibits that were already in the Court file or used in this case Afternoon Session Link Rockenbach PA copy of the disc entitled Epstein Bate Stamp that is the subject of the dispute will be filed under seal Afternoon Session Link Rockenbach PA to retain Fowler Whites boxes including the original disc Afternoon Session On Friday March at p.m the Fourth District Court of Appeal entered its Order staying the state court action pending its review PLAINTIFF/COUNTER-DEFENDANTS COMPLIANCE Plaintiff/Counter-Defendant Jeffrey Epsteins counsel Link Rockenbach PA have complied with the Courts rulings at the March hearing as follows Link Rockenbach PA has not made any further dissemination of the documents included in the Appendix in Support of Epsteins Response in Opposition to Edwards Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence trial exhibits or other documents from the disc that Edwards has asserted privilege claims over On March Link Rockenbach PA notified its client its co-counsel Jack Goldberger its litigation team working on this matter and its expert Timothy Chinaris to destroy all hard copies and electronic versions of the documents obtained from the disc and any copies of the discs that they had in their possession On March Epstein filed his Notice of No Objection to Attorney Paul Cassell on Behalf of L.M E.W and Jane Doe or Defendant/Counter-Plaintiff Bradley Edwards Moving to Seal Court Records Until the Court Makes a Determination on How the Documents Shall be Treated Link Rockenbach PA is assisting Edwards counsel to seal the redacted version of D.E Epsteins Notice of Filing Redacted Appendix in Support of Response in Opposition to Edwards Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence and D.E Motion for Court to Declare Relevance and Non-Privileged Nature of Documents and Request for Additional Limited Discovery Evidentiary Hearing and Appointment of Special Master Link Rockenbach PA has destroyed its paper copy of the Redacted Appendix that was filed in the Court file and has deleted the electronic version from its system Link Rockenbach PA has placed the Unredacted Appendix that was served but not filed in a sealed box that will be maintained in its office unopened for appellate purposes In Edwards March Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike All Exhibits and Any Reference to Documents Containing Privileged Matters Listed on Edwards Privilege Log Edwards alleged the following exhibits identified by Epstein were privileged No Ex No Bates No App No No Ex No Bates No App No Edwards also objected to the following additional exhibits as being late disclosed No Ex No Bates No App No No Ex No Bates No App No Legamaro Depo Ex Legamaro Production Link Rockenbach PA has marked the exhibits identified above and placed them in a sealed envelope for filing with the Court under seal once the stay is lifted in order to preserve Epsteins appellate record Link Rockenbach PA will retain a set of these exhibits in a sealed envelope in the sealed box maintained in its offices for appellate purposes With the exception of those documents it is maintaining in a sealed box for appellate purposes Link Rockenbach PA has destroyed all hard copies of the documents it reproduced from the disc that Edwards has identified as privileged Link Rockenbach PA has placed its copy of the disc in a sealed envelope which will be filed under seal with the Court once the stay is lifted Link Rockenbach PA has placed Fowler Whites original disc in a sealed envelope which will be maintained with its original records at the offices of Link Rockenbach PA until further rulings by the Court Link Rockenbach PA will maintain control of the Fowler White boxes until further rulings by the Court Link Rockenbach PA has deleted the electronic duplicate of the disc and the electronic version of the exhibits identified above from its computer system and Dropbox Link Rockenbach PA will work with its IT personnel to remove copies of any documents Edwards has claimed as privileged from its e-mail servers CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on March via e-mail and will be served with the Court once the stay is lifted LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Rachel Glasser FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Rachel linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL brad epllc.com staff.efile pathotojustice.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL njs FLAAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Marc Nurik Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL marc nuriklaw.com Counsel for Defendant Scott Rothstein Paul Cassell University Salt Lake City UT cassellp law utah edu Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Filing E-Filed PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS UPDATED NOTICE OF COMPLIANCE WITH COURTS RULINGS Plaintiff/Counter-Defendant Jeffrey Epstein Epstein hereby updates his March Notice of Compliance with the Courts March rulings and states THE COURTS RULINGS At that hearing the Court made the following rulings As to lntervenors E.W L.M and Jane Doe request to temporarily seal the pleadings relating to the e-mails the Court granted the request and asked for a proposed Order Morning Session The sanitized redacted version of Epsteins Notice of Filing Appendix shall be filed under seal Afternoon Session In order for Epstein to preserve his rights concerning the Courts rejection of the last-minute request for an in-camera inspection and the striking of his newly Although no written Order has been entered yet on Defendant/Counter-Plaintiff Bradley Edwards March Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards Privilege Log Epstein has complied with and will continue to comply with the Courts rulings on the record disclosed exhibits Epstein shall file under seal the newly disclosed trial exhibits which Edwards has claimed are privileged Afternoon Session These do not include exhibits that were already in the Court file or used in this case Afternoon Session Link Rockenbach PAs copy of the disc entitled Epstein Bate Stamp that is the subject of the dispute will be filed under seal Afternoon Session Link Rockenbach PA to retain Fowler Whites boxes including the original disc Afternoon Session On Friday March at p.m the Fourth District Court of Appeal entered its Order staying the state court action pending its review That stay was lifted in part on March and Epstein hereby updates his Notice of Compliance PLAINTIFF/COUNTER-DEFENDANTS COMPLIANCE Plaintiff/Counter-Defendant Jeffrey Epsteins counsel Link Rockenbach PA has complied with the Courts rulings at the March hearing as follows Link Rockenbach PA has not made any further dissemination of the documents included in the Appendix in Support of Epsteins Response in Opposition to Edwards Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence the newly disclosed trial exhibits in which Edwards claims a privilege or other documents from the disc that Edwards has asserted privilege claims over Neither Epstein nor his general counsel Darren Indyke were ever provided with a copy of the disc nor did they review or have access to the disc or the discs contents Epstein and his general counsel also never received the disc or alleged privileged documents from the Fowler White firm or any other former counsel Rather Epstein and his general counsel were provided with select e-mails by Link Rockenbach PA that were included in the Appendix or identified as trial exhibits Immediately after the hearing on March Link Rockenbach PA notified its client its clients general counsel who was at the hearing its co counsel Jack Goldberger who was at the hearing and its litigation team working on this matter to destroy all hard copies and electronic versions of the documents obtained from the disc Timothy Chinaris a former Ethics Director of the Florida Bar who provided an expert affidavit in this action was also not provided with a copy of the disc but rather received a binder in paper form containing the unredacted Appendix Mr Chinaris was instructed to destroy the binder along with any electronic copies he may have had Mr Chinaris confirmed his compliance with this request Neither the disc nor any of its contents were ever provided to the Gunster firm or any of its attorneys nor were the contents of the disc ever discussed with them On March Epstein filed his Notice of No Objection to Attorney Paul Cassell on Behalf of L.M E.W and Jane Doe or Defendant/Counter-Plaintiff Bradley Edwards Moving to Seal Court Records Until the Court Makes a Determination on How the Documents Shall be Treated Mr Cassells request was addressed and granted by stipulation at the March hearing Both Mr Cassell and Edwards counsel however failed to provide the Court with a proposed order at the hearing which would have resulted in the immediate sealing of two docket entries that had not yet been opened to the public While Mr Cassell and Edwards counsel had ample time during the hearing to have an Order prepared and signed by the Court a proposed order was not circulated to Epsteins counsel until the following afternoon Friday March Judge Hafele had made known to the parties that he would not be in Court on March because of the Bench Bar Conference but he advised where he could be found if needed Nevertheless the Fourth DCAs stay was entered on March within hours of the transmittal of the proposed order Furthermore on the evening of March the Clerk opened the two docket entries that are at issue to the public During the weekend of March and Epsteins counsel worked tirelessly with Edwards counsel to obtain emergency relief from the duty judge to seal the two docket entries at issue The duty judge however deferred the matter to Judge Hafele Accordingly on the morning of March Epsteins and Edwards counsel went before the Court at a.m and obtained an Order nunc pro tune sealing the two docket entries at issue Epsteins Notice of Filing Redacted Appendix in Support of Response in Opposition to Defendant/Counter-Plaintiff Bradley Edwards Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence D.E a 353-page filing with attachments containing actual emails as well as a summary of its contents and Epsteins Motion for Court to Declare Relevance and Non Privileged Nature of Documents and Request for Additional Limited Discovery Evidentiary Hearing and Appointment of Special Master D.E The Clerk then sealed the two docket entries which had been open to the public for more than hours Link Rockenbach PA destroyed its paper copy of the Redacted Appendix that was filed in the Court file and deleted the electronic filed version from its system Link Rockenbach PA placed the Unredacted Appendix that was served but not filed in a sealed box that will be maintained in its office unopened for appellate purposes In Edwards March Motion to Strike Epsteins Untimely Supplemental Exhibits and to Strike All Exhibits and Any Reference to Documents Containing Privileged Matters Listed on Edwards Privilege Log Edwards alleged the following exhibits identified by Epstein were privileged No Ex No Bates No App No No Ex No Bates No App No Edwards also objected to the following additional exhibits which were printed from the disc as being late disclosed No Ex No Bates No App No No Ex No Bates No App No Legamaro Depo Ex Legamaro Production Edwards objected to other documents Epstein identified as newly disclosed trial exhibits but those were obtained from public sources over which Edwards and Mr Cassell cannot assert privilege claims and therefore they are not included as part of this Notice of Compliance Link Rockenbach PA placed an exhibit sticker on the newly disclosed exhibits identified above to correspond with Epsteins Clerks Trial Exhibit List Two sets of those exhibits were made One has been retained by Link Rockenbach PA in a sealed envelope in a sealed box maintained at its offices for appellate purposes The other set was initially retained in a sealed envelope at Link Rockenbach PA however on March in light of the lifting of the Fourth District Court of Appeals stay in part those exhibits were filed under seal Epstein has also moved the Court to Make the Court Records Confidential in compliance with the th Judicial Circuits Administrative Order and set that Motion for hearing on April With the exception of the trial exhibits and appendix items identified above which Link Rockenbach PA is maintaining in a sealed box for appellate purposes Link Rockenbach PA has destroyed all hard copies of the documents it reproduced from the disc that Edwards has identified as privileged Link Rockenbach PA placed its copy of the disc in a sealed envelope which it retained at its offices until the stay was lifted In that regard on March Link Rockenbach PA filed the disc under seal and moved the Court to make the court records confidential in compliance with the th Judicial Circuits Administrative Order That Motion is set for hearing on April Link Rockenbach PA placed Fowler Whites original disc in a sealed envelope which will be maintained with Fowler Whites original records at the offices of Link Rockenbach PA until further rulings by the Court Link Rockenbach PA will maintain control of the Fowler White boxes until further rulings by the Court Link Rockenbach PA has deleted the electronic duplicate of the disc and the electronic version of the exhibits identified above from its computer system and Dropbox the online service by which those documents were transmitted to counsel of record Link Rockenbach PA began deleting electronic documents from its system and planned to work with IT personnel to remove copies of any documents Edwards has claimed as privileged from its e-mail servers In light of Edwards objection to the deletion of electronic documents however Link Rockenbach PA has not taken further steps to delete electronic documents The Court made no rulings on the preservation of these documents and Link Rockenbach PA does not agree that the review Edwards demanded is appropriate Until the Court rules otherwise however Link Rockenbach PA will not delete any further electronic documents and will work with its IT personnel to preserve those documents CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on March through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Rachel Glasser FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Rachel linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen Terry David Vitale Jr Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Philip Burlington Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com Co-Counsel for Defendant/Counter-Plaintiff Counsel for Defendant Scott Rothstein Bradley Edwards Jack A Goldberger Paul Cassell Atterbury Goldberger Weiss P.A University Australian Avenue Suite Salt Lake City UT West Palm Beach FL cassellp law.utah.edu goldberger agwpa.com Limited Intervenor Co-Counsel for L.M E.W smahoney agwpa.com and Jane Doe Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ 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