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v. Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 8 v. Epstein, Case No. 09-80802 (S.D. Fla. 2009)). 6 See also (A-11 at ¶ 6) (citing Jn re: Jane Doe, Case No. 08-80736 (S.D. Fla. 2008)). References to "Supp.A." correspond to the supplemental appendix filed by the Post simultaneous with this bri
rial; and 3. closure would be effective in protecting the rights of the accused, without being broader than necessary to accomplish this purpose. Miami Herald Publ'a Co. v. Lewis, 426 So. 2d 1, 6 (Fla. 1982). This test, as well as the standard announced in Barron v. Florida Freedom Newspapers, Inc. 531 So. 2d 113 (F
sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe
records. See Barron v. Florida Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'a Co. v. Lewis, 426 So. 2d I, 7 (Fla. 1982) (news media must be given an opportunity to be heard on question of closure). 09/12/2019 P CONFIDENTIAL Age
d on FLSD Docket 06/08/2009 Page 5 of 11 CASE NO: 08-CV-80119-MARRA/JOHNSON Background Defendant Epstein has filed a boilerplate motion to strike Jane Doe's trial date — and numerous other consolidated cases involving similar allegations of his sexual abuse of minors - for an unspecified period of time,
records. See Barron v. Florida Freedom Newspapers. Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'a Co. v. Lewis 426 So. 2d I, 7 (Fla. 1982) (news media must be given an opportunity to be heard on question of closure). EFTA00182785 08/05/2009 10:01
Entities connected to both Jane Doe and Miami Herald Publ'a Co.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONRobert D. Critton
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONMichael J. Pike
PERSON
Alexander Acosta
PERSONScott Rothstein
PERSONRobert C. Josefsberg
PERSONJack Scarola
PERSONKatherine W. Ezell
PERSONRichard Horace Willits
PERSONJack Patrick Hill
PERSONIsidro Manuel Garcia
PERSON