Epstein Secrets

5 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida on Wednesday, April 20, 2011 at 8:45 a.m., the following: 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

TRA-JUDICIAL STATEMENTS AND COMMENTARY TO TILE 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 Slide cx. rel. Miami

O. 502009CA0408003OOC3CMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,

air 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 Supreme Court in McIntosh recognized that restrictions on extra- judicial comment are within the pow

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,

power to control professional conduct. State ex rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d at 910. Thereafter, the Supreme Court in McCrary stated: "Prohibition on comment is an acceptable alternative to prior restraint." Florida Freedom Newspapers, Inc. v. McCrary, 520 So. 2d at 35-36 (

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

ir 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 McIntosh recognized that restrictions on extrajudicial comment are within the power of

attached), you are quoted as making the following statements: 1. "We would be 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 ex

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 t

with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional deta

ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,

ir 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 McIntosh recognized that restrictions on extrajudicial comment are within the power of

OTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRAJUDICIAL STATEMENTS AND COMMEN

EXTRAJUDICIAL 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 Amended Motion for a Pr

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

n the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very substantial cl

LAZA, 1395 BRICKELL AVENUE, 14m FLOOR. MIAMI, FLORIDA 33131* (305) 789-9200 EFTA00583815 CASE NO. 50 2009 CA 040800 XXXXMB AG Newspapers, Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988) (there is no constitutional impediment to a court prohibiting counsel from making prejudicial statements that are int

SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRAJUDICIAL STATEMENTS AND COMMEN

EXTRAJUDICIAL 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 Amended Motion for a Pr

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

n the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very substantial cl

he media are permissible for good cause shown in order to assure a fair trial. See McIntosh, 340 So. 2d at 910; Florida Freedom Newspapers, Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988) (there is no constitutional impediment to a court prohibiting counsel from making prejudicial statements that are int

From: "Jill McCrary" To: "Lesley Groff" <Ma Subject: RE: Jeffrey Epstein Date: Mon, 13 Jun 2011 18:11:34 +0000 You're welcome. Original Message From: Lesley Groff [mailto: Sent: Monday, June 13, 2011 1:11 PM To: Ji

ry" To: "Lesley Groff" <Ma Subject: RE: Jeffrey Epstein Date: Mon, 13 Jun 2011 18:11:34 +0000 You're we

ll McCrary" To: "Lesley Groff" <Ma Subject: RE: Jeffrey Epstein Date: Mon, 13 Jun 2011 18:11:34 +0000 Y

iginal Message > From: Lesley Groff [mailto: > Sent: Monday, June 13, 2011 12:35 PM > To: Jill McCrary > Subject: Jeffrey Epstein > • Hello Ms. McCrary. > Jeffrey Epstein will be attending the Zwirn deposition tomorrow at the > Susman office in NY...I know it is an all day event...but what time >

, 2011 1:06:07 PM EDT To: "Bill Dunseth" Susman" < McCrary" < "Seth Ard" Subject: JE Deposition Corrections S , "Darren Indyke" c>, "Harry , "Jeff Epstein" <jeevacation mail.com>, "Jill , "Jonathan J. Ross" , "Steve Susman" See the attached memo and a copy of your deposition. EFTA00433641

ections S , "Darren Indyke" c>, "Harry , "Jeff Epstein" <jeevacation mail.com>, "Jill , "Jonathan J. R

en Indyke ca. To: Lesley Groff <1 Subject: Fwd: JE Deposition Corrections Date: Thu, 19 May 2011 15

******************************** Begin forwarded message: From: "Harry Susman" < Date: May 18, 2011 1:06:07 PM EDT To: "Bill Dunseth" Susman" < McCrary" < "Seth Ard" Subject: JE Deposition Corrections S , "Darren Indyke" c>, "Harry , "Jeff Epstein" <jeevacation mail.com>, "Jill , "Jonathan J.

message: From: "Harry Susman" < Date: May 18, 2011 1:06:07 PM EDT To: "Bill Dunseth" < Susman" < McCrary" < , "Darren Indyke" c >, "Harry , "Jeff Epstein" <[email protected]> "Jill , "Jonathan J. Ross" EFTA00433642 >, "Seth Ard" < > Subject: JE Deposition Corrections See the attached memo an

Crary" < , "Darren Indyke" c >, "Harry , "Jeff Epstein" <[email protected]> "Jill , "Jonathan J. Ro

roff <1 To: "Harry Beller, I." -1 Subject: Fwd: JE Deposition Corrections Date: Thu, 19 May 2011 15

ke, PLLC —All rights reserved. Begin forwarded message: From: "Harry Susman" < Date: May 18, 2011 1:06:07 PM EDT To: "Bill Dunseth" < Susman" < McCrary" < , "Darren Indyke" c >, "Harry , "Jeff Epstein" <[email protected]> "Jill , "Jonathan J. Ross" EFTA00433642 >, "Seth Ard" < > Subject:

brary/Recents/Recents SourceType Recents First Jeffrey epstein Email (Email) [email protected] ID 1428976

brary/Recents/Recents SourceType Recents First Jeffrey epstein Email (Email) [email protected] ID

h HD Path /thers/jee/Library/Application Support/AddressBook/AddressBook-v22.abcddb SourceType Mac AddressBook First Jill EFTA00506695 Last McCrary Email (Work) Creation Date 2012-02-01 16:53:54 (UTC) Modification Date 2014-11-06 18:07:17 (UTC) ID 1425 Contact Source Device NYCO24328.aff4