Epstein Secrets

nd 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 Supreme Court in

340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers, Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988). The Florida Supreme Court in McIntosh recognized that restrictions on extrajudicial comment are within the power of the trial judge when it said: Limitation placed on lawyers, litigants

communications by you and Mr. Edwards, as attorneys, with the media are also limited by the requirements of Rule 4-3.6 of the Rules Regulating The Florida Bar. Rule 4-3.6., entitled "Trial Publicity," states: (a) Prejudicial Extrajudicial Statements Prohibited. A lawyer shall not make an extrajudicial sta

ublicity in this matter concerning Mr. Epstein's alleged sexual abuse of or being with minor females, consistent with 4.3-6 of the Rules Regulating the Florida Bar. We trust that you will agree to a swift and amicable resolution of this issue. Otherwise, we will seek judicial intervention and ask Judge Crow to

nd 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 Supreme Court in

340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers. Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988). The Florida Supreme Court in McIntosh recognized that restrictions on extrajudicial comment are within the power of the trial judge when it said: Limitation placed on lawyers, litigants

sexual abuse of or being with minor females; or, (2) is injurious to Mr. Bradley Edwards' reputation, consistent with 4.3-6 of the Rules Regulating the Florida Bar. We trust that you will agree to a swift and amicable resolution of this issue. Otherwise, we will seek judicial intervention and ask Judge Crow to

communications by you and Mr. Edwards, as attorneys, with the media are also limited by the requirements of Rule 4-3.6 of the Rules Regulating The Florida Bar. Rule 4-3.6., entitled "Trial Publicity," states: (a) Prejudicial Extrajudicial Statements Prohibited. A lawyer shall not make an extrajudicial sta

icial 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 - EFTA00616237 CAS

r litigants and the media are permissible for good cause shown in order to assure a fair trial. See State ex. rel. Miami I Jerald 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). 7. The Florida Supreme Court

fendant, JEFFREY EPSTEIN, respectfully requests this Court, pursuant to the foregoing authorities and consistent with 4.3-6 of the Rules Regulating the Florida Bar, to issue a Protective Order barring Mr. Jack Scarola, Defendant/Counter-Plaintiff Mr. Bradley J. Edwards, and their respective agents and employees

ion his case in the public light. This is clearly effecting Epstein's right to obtain a fair and just trial. State ex rel. Miami Herald Pub. Co. v. McIntosh, 340 So.2d 904, 910-11(1976)(Muzzling lawyers who may wish to make public statements to gain public sentiment for their clients has long been recog

ry of a video deposition to the media. See infra for argument on media not having a right to pretrial discovery. 13. Rule 4-3.6, Rules Regulating the Florida Bar, states, in pertinent part: (a) Prejudicial Extrajudicial Statements Prohibited. A lawyer shall not make an extrajudicial statement that a reasonab

ocket 0721/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. oe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya P.A. Counsel for Defendant Haley Robson Bruce E. Reinhart, Esq. Bruce E. Reinhart, P.A. n an •ra e en Robert D. Critto

25 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates Reportiny and lranscrirrix, inc Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't don't tell me w

Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach, Florida 33401 Fax. 561 682-3206 Counsel for Defenda

e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 nsor & Associates ReparlillS and 1.71111Gliptill11. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 6 7 8 with him. Where did you meet him? 9 10 friend's house. 11 12 13

.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach Florida 33401 Fax. III Counsel for Defendant Bruce

5 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 74 of 100 sor & Associates [tenoning and Inniscrivinn. Inc. Page 48 1 Florida Bar? 2 A. I did not select him. 3 Q. Who did? 4 A. My father. 5 Q. Did you ever meet Mr. Herman? 6 A. Once. 7 Q. Don't -- don't tell me