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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,
ns of children, allegedly at his Florida mansion in most cases, where the Duke enjoyed holidays and massages. Jack Scarola, the lawyer representing Mr Edwards, told The Daily Telegraph: -We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein. 'We want to obtain addi
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
ns of children, allegedly at his Florida mansion in most cases, where the Duke enjoyed holidays and massages. Jack Scarola, the lawyer representing Mr Edwards, told The Daily Telegraph: "We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein. "We want to obtain addi
Sent Fri 10/9/2009 9:20:47 PM Subject: Re: proposed answer if mon thinks advisable Please call me again Message sent from my mobile device From: Jeffrey Epstein To: Mortimer Zuckerman Sent: Frl Oct 09 13:33:43 2009 Subject: proposed answer If mort thinks advisable George , motions have been made for sanct
as he is trying to build a practice. To publish some of both his and Mr Edwards statements would be wrong and in re. Ms Maxwell, defamatory. I. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Asking someone for sex for money. No sex occurred 2. He also plead guilty to procuring minors for pros
again Message sent from my mobile device From: Jeffrey Epstein To: Mortimer Zuckerman Sent: Frl Oct 09
d be wrong and in re. Ms Maxwell, defamatory. I. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Aski
stablishments in which she admitted working require proof of age. Rc the rest of the questions„ These are all malicious fabrications designed to get Mr Edwards clients more money than they normally receive though she did testify under oath that she made as much as 2000 per day. The information contained i
y 2011 • ThD k fYrk, 51, pictured with his arm around the bare midriff of • Mother-of-three spent four years as millionaire's personal masseuse • Epstein trained her 'as a prostitute for him and his friends' Serious doubts are being cast on Prince Andrew's suitability to represent Britain following re
yalty'. Here, Tom Leonard reveals the astonishing background to the case. The new Gatsby Even by the rags-to-riches-to-rags mythology of New York, Jeffrey Epstein's ascent and subsequent humbling has been breathtaking. The son of a parks department employee, he was plucked from obscurity as a Manhattan private
on an Aids mission to Africa. He is a noted patron of science and — say awed observers — has a brilliantly acute mind. One says: 'You spend time in Jeffrey's company and you come away enriched, and not diminished.' Epstein's friends include not only Mr Clinton but Donald Trump, former Israeli prime mini
isks ambassador job as underage sex case girl reveals meeting him I Mail... Page 7 of 16 'If it you or I did this, we'd be in prison for life,' said Mr Edwards. However, the girls have been allowed to take civil action and Epstein has so far made 40 hefty out-of-court settlements. Several girls said Ghisla
ating to Prince Andrew on 6 March 2011 in the Sunday Telegraph you reported that our client is accused In court papers of introducing young women to Epstein at his Florida mansion". You qualified that by saying "although she has never been arrested nor charged with any offence. In fact, it goes far wid
ent was not aware of any improper or unlawful conduct by Jeffery Epstein. 2. Our client has not been named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar conduct by anyone else. 3. Further, no one has at any time even written to our client making any claims again
n named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar
y claim she was aware of was a claim made by You refer to allegations that have been promoted by and her attorney who we believe is Brad Edwards. Mr Edwards is the former business partner of Scot Rothstein who is currently serving 50 years having created false claims and cases against Jeffery Epstein. Y
ating to Prince Andrew on 6 March 2011 in the Sunday Telegraph you reported that our client is accused In court papers of introducing young women to Epstein at his Florida mansion". You qualified that by saying "although she has never been arrested nor charged with any offence. In fact, it goes far wid
ent was not aware of any improper or unlawful conduct by Jeffery Epstein. 2. Our client has not been named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar conduct by anyone else. 3. Further, no one has at any time even written to our client making any claims again
n named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar
y claim she was aware of was a claim made by You refer to allegations that have been promoted by and her attorney who we believe is Brad Edwards. Mr Edwards is the former business partner of Scot Rothstein who is currently serving 50 years having created false claims and cases against Jeffery Epstein. Y
ating to Prince Andrew on 6 March 2011 in the Sunday Telegraph you reported that our client is accused In court papers of introducing young women to Epstein at his Florida mansion". You qualified that by saying "although she has never been arrested nor charged with any offence. In fact, it goes far wid
ent was not aware of any improper or unlawful conduct by Jeffery Epstein. 2. Our client has not been named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar conduct by anyone else. 3. Further, no one has at any time even written to our client making any claims again
n named as a party in any proceedings relating to Jeffrey Epstein's unlawful conduct or any other similar
y claim she was aware of was a claim made by You refer to allegations that have been promoted by and her attorney who we believe is Brad Edwards. Mr Edwards is the former business partner of Scot Rothstein who is currently serving 50 years having created false claims and cases against Jeffery Epstein. Y
he is trying to build a practice. To publish some of both his and Mr .Edwards statements would be wrong and in re. Ms Maxwell, defamatory. 1. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Asking someone for sex for money. No sex occurred 2. He also plead guilty to procuring minors for pros
be wrong and in re. Ms Maxwell, defamatory. 1. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Aski
tablishments in which she admitted working require proof of age. Re the rest of the questions„ These are all malicious fabrications designed to get Mr Edwards clients more money than they normally receive though she did testify under oath that she made as much as 2000 per day. EFTA00584404
he is trying to build a practice. To publish some of both his and Mr .Edwards statements would be wrong and in re. Ms Maxwell, defamatory. 1. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Asking someone for sex for money. No sex occurred 2. He also plead guilty to procuring minors for pros
be wrong and in re. Ms Maxwell, defamatory. 1. Mr. Epstein plead guilty to soliciting prostitutes. i.e. Aski
tablishments in which she admitted working require proof of age. Re the rest of the questions„ These are all malicious fabrications designed to get Mr Edwards clients more money than they normally receive though she did testify under oath that she made as much as 2000 per day. EFTA_R1_02004177 EFTA02684
Entities connected to both Jeffrey Epstein and Mr Edwards

Marc Rich
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Bill Clinton
PERSON
U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSONScott Rothstein
PERSON
Les Wexner
PERSONJack Scarola
PERSONSpencer Kuvin
PERSONThe New York Post
ORGANIZATION
New York Daily News
ORGANIZATIONFlorida Bar
ORGANIZATION
Robert Maxwell
PERSON
Central Park
LOCATION
Katie Couric
PERSON