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Andrew has been in the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." [Exhibit I]. 3. That same day, the Palm Beach Daily News published an article entitled "Jeffrey Epstein address book 'Holy Grail' of famous manes." [Exhibit 2]. This article refers to the fact that "[t]he
ol and prohibit such extra- judicial commentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair trial. See State ex. rd. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976). Courts in Florida may take steps to protect against pretrial publicity. See Shepnard v. - 2 - EFTA00
Andrew has been in the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." [Exhibit I]. 3. That same day, the Palm Beach Daily News published an article entitled "Jeffrey Epstein address book 'Holy Grail' of famous manes." [Exhibit 2]. This article refers to the fact that "[t]he
mmunications between lawyers and/or litigants and the media are permissible for good cause shown in order to assure a fair trial. See $tate ex. rel. Miami Herald Publishing Co. v. Mslntosh 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers. Inc. v, McCrary, 520 So. 2d 32, 35 (Fla. 1988). 7. The Florida
ompany of under-aged children." Miami • Fort Lauderdale • West Palm Beath EFTA00599605 Jack Scarola, Esq. March 17, 2011 Page 2 That same day, the Palm Beach Daily News published an article entitled "Jeffrey Epstein address book `Holy Grail' of famous manes." (copy attached). This article refers to the fact that "[
munications between the media and lawyers and/or litigants are permissible for good cause shown in order to assure a fair trial. See State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers. Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988). The Florida Supr
hat Prince Andrew has been in the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." 5. On March 11, 2011 the Palm Beach Daily News published an article entitled "Jeffrey Epstein Address Book `Holy Grail' of Famous Names." (Exhibit 5). This article refers to the fact that "[t]he
o insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. reL Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); Sentinel Commc'n Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by a
hat Prince Andrew has been in the company of Mr. Epstein while Mr. Epstein has been in the company of under-aged children." 5. On March 11, 2011 the Palm Beach Daily News published an article entitled "Jeffrey Epstein Address Book `Holy Grail' of Famous Names." (Exhibit 5). This article refers to the fact that "[t]he
insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); Sentinel Commc'n - 4 - FOIVLER WHITE BURNER P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14u ,
Entities connected to both the Palm Beach Daily News and Miami Herald Publishing Co.

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSONScott Rothstein
PERSON
Michael Reiter
PERSON
George W. Bush
PERSON
Barry Diller
PERSON
United States
LOCATIONthe Southern District
LOCATIONJack Scarola
PERSON
the United States Supreme Court
ORGANIZATION
Marc Rich
PERSONSpencer Kuvin
PERSON
McIntosh
PERSON