Epstein Secrets

Y B uRLINcTorg OFVICE IN THE GROVE, PENTHOUSE 2699 SOUTH BAYSHORN DRIVE MIAMI, FLORIDA 33(33 F: Email: www.coffeyburlingtoo.com EFTA00223348 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. UNDER SEAL -CIV.MARRA EDWARD MORSE and CAROL MORSE, Plaintiffs. vs. JAN JONES INTERNATIONAL, INC. ailda

llants, I JAN JONES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defendant-Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitione

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

by electronic mail through the Court's CM/ECF system to those parties who are registered users. I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2

o or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or whic

this Court upon its execution. WITNESS THE HONORABLE WILLIAM J. J. ZLOCH UNITED STATES DISTRICT JUDGE DATE: 4 01/" .0)7 STEVEN LARIMORE, CLERK UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA BY: DEPUTY CLERK EFTA00725183

y Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or whic

by electronic mail through the Court's CM/ECF system to those parties who are registered users. I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2

o or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or whic

Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an action pending in the United States District Court for the Southern District of Florida captioned Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order pursuant

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

Fed. R. Civ. Proc. 45(cX3XAXiii) quashing subpoenas ad testificanduni and duces twain served on than by plaintiff Jane Doe in an action pending in the United States District Court for the Southern District of Florida captioned Doe v. Jeffrey Epstein, No. 08-cv-80893-1CAM, or in the alternative for a Protective Order pursuant

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

by electronic mail through the Court's CM/ECF system to those parties who are registered users. I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2

aintiff and the law firm of RRA. 3. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or whic

lants, v. JAN JONES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defendant-Appellee. In re EDWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Mana), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioner

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

ntered on FLSD Docket 05/22/2009 Page 1 of 4 EXHIBIT A to Plaintiffs Jane Doe 101 and Jane Doe 102's Motion for No-Contact Order EFTA01625662 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related Cases: 0

partner, Mr. Luther, had a court reporter and a videographe• present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 EFTA01625667 Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/