PAUL G. CASSELL S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake Telephone [email protected] March 4, 2018 Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Via email: [email protected] [email protected] Re: Your Possession of Confidential and Privileged Materials Dear Mr. Link and Ms. Rockenbach: I write on behalf of three of my clients, whom I will refer to as L.M., E.W., and Jane Doe. I believe you are familiar with their identities as child sexual assault victims of your client, Jeffrey Epstein. It has come to my attention that you are in possession of attorney-client and work-product protected materials to which my clients are entitled to confidentiality. For example, it is my understanding that you have in your possession emails between Mr. Bradley J. Edwards and me discussing litigation strategies and other attorney-client and work-product protected information in connection with civil cases prosecuted against Jeffrey Epstein for sex offenses he committed against children (e.g., Jane Doe v. Epstein, No. 9:08-cv-80893-Marra/Johnson (S.D. Fla.)) and/or a related federal Crime Victims' Rights Act lawsuit currently pending in the U.S. District Court for the Southern District of Florida (e.g., Jane Does 1 Sr 2. v. United States, No. 9:08-cv-80736-KAM (S.D. Fla.)). You also appear to have other communications between Mr. Edwards and other attorneys that are similarly protected and related to those cases. It appears that many of these confidential and protected materials have been listed in Plaintiff/Counter- Defendant Jeffrey Epstein's Notice of Service of Unredacted Appendix in Support of Response in Opposition to Defendant/Counter-Plaintiff Bradley J. Edwards' Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence (hereinafter "Notice of Unredacted Materials"), Epstein v. Edwards, Ca