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idually, and individually, Defendants. Complex Litigation, Fla. R. Civ. Pro. 1201 Case No. 50 2009 CA 040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRA-JUDICIAL STATEMENTS AND COMMENTARY TO T
XTRA-JUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective O
mentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair trial. See State ex. rd. Miami H
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv
ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,
moved to the US in 1991 after the death of her father and became a fixture on the Manhattan party circuit, where she befriended Jeffrey Epstein. ■ Goga Ashkenazi, 31, a glamorous Kazakh oil tycoon, claims to be a "close friend" of Prince Andrew. Ashkenazi, an Oxford-educated socialite and entrepreneur, said:
ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where
s has a new admirer. Spencer Kuvin, a Florida lawyer who has (ought several cases for young women alleging sexual abuse by the disgraced billionaire Jeffrey Epstein, is delighted — and relieved — that newspapers are now examining Prince mew's relationship with the convicted paedophile. "lam glad the British pre
very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where, how frequently and the extent to which it involved the transport of children inside and outside
with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional deta
moved to the US in i991 after the death of her father and became a fixture on the Manhattan party circuit, where she befriended Jeffrey Epstein. ■ Goga Ashkenazi, 31, a glamorous Kazakh oil tycoon, claims to be a "close friend" of Prince Andrew. Ashkenazi, an Oxford-educated socialite and entrepreneur, said:
From: Warren Eisenstein <MI > To: Jeffery Edwards <[email protected]> Date: Sun, 21 Aug 2011 13:23:10 +0000 You were mentioned twice in the September W magazine article about Goga Ashkenazi Ke
o: Jeffery Edwards <[email protected]> Date: Sun, 21 Aug 2011 13:23:10 +0000 You were mentioned twice in the September W magazine article about Goga Ashkenazi Keep on Pushin' Warren EFTA00682961
Entities connected to both Jeffrey Epstein and Goga Ashkenazi

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Bradley Edwards
PERSON
Bill Clinton
PERSON
U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSONScott Rothstein
PERSONJack Scarola
PERSONSpencer Kuvin
PERSONThe New York Post
ORGANIZATION
New York Daily News
ORGANIZATIONFlorida Bar
ORGANIZATION
Robert Maxwell
PERSON
Central Park
LOCATION
Duchess
PERSON
The Daily Telegraph
ORGANIZATION
the United States Supreme Court
ORGANIZATIONthe Palm Beach Daily News
ORGANIZATION