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,

his Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extra-Judicial Statements and Commentary to the Media and Press, and, as grounds therefor, states: I. On March 11, 2011, the British publication "The Telegraph" published an article entitled "Convicted paedoph

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,

his Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extra-Judicial Statements and Commentary to the Media and Press, and, as grounds therefor, states: 1. On March 11, 2011, the British publication "The Telegraph" published an article entitled "Convicted paedoph

Epstein v. Rothstein & Edwards Case No.: 50-2009 CA 040800 AG SCHEDULE OF UPCOMING DEPOSITIONS DATE TIME LOCATION DESCRIPTION NOTES 5/17 (Tentative)

ear for Further Deposition; 5). Motion for Protective Order to Preclude Scarola Et Edwards from making Extra Judicial Statements and Commentary to the Media and Press (Judge Crow) Edwards' Motions: 1). Motion to Dismiss the Amended Complaint; 2). Motion for Protective Order and Objections to Canceled Notice of

Epstein v. Rothstein & Case No.: 50-2009 CA 040800 AG SCHEDULE OF UPCOMING DEPOSITIONS DATE TIME LOCATION DESCRIPTION NOTES 5/17 (Tentative) 10:00am

uestions and Appear for Further Deposition; n for Protective Order to Preclude Scarola Et from making Extra Judicial Statements and Commentary to the Media and Press (Judge Crow) Motions: 1). Motion to Dismiss the Amended Complaint; 2). Motion for Protective Order and Objections to Canceled Notice of Taking De