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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,
d cause shown in order to assure a fair 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 a
in the above matter. I have prepared a proposed Order, which I believe accurately reflects your ruling at the hearing on June 26, 2009 on Defendant Jeffrey Epstcin's Motion to Stay Disclosure of the Non-Prosecution Agreement and Addendum Pending Review. By copy of this letter, I am providing all counsel of recor
rt considers in connection with sentencing. Sarasota Herald Tribune. Div See. e.g.. Doe v. Epstein Case No. 08-80069 (S.D. Fla. 2008); Doe No. 2 v. Epstein. Case No. 08-80119 (S.D. Fla. 2008); Doe No. 3. v. Epstein, Case No. 08-80232 (S.D. Fla. 2008); Doe No. 4._vinstein, Case No. 08-80380 (S.D. Fla. 2
tial. The only matter before the court today was Defendant Epstein's Motion for a Stay which the court denied. Cont
effrey Epstein Dear Judge Colbath: On behalf of Mr. Epstein, we strongly object to the proposed order submitt
VIA FEDERAL EXPRESS OVERNIGHT MAIL The Honorable Jeffrey Colbath Fifteenth Judicial Circuit-Palm Beach P
media, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and records. So Barron v Florida Freedom Newspapers. Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Pybl'g Co. 426 So. 2d I, 7 (Fla. 1982) (news med
EY EPSTEIN, Defendant. CASE NO.: 09-80469-CIV-MARRA-JOHNSON CASE NO.: 09-80591-CIV-MARRA-JOHNSON CASE NO.: 09-80656-CIV-MARRA/JOHNSON DEFENDANT, JEFFREY EPSTEIN'S REPLY TO JANE DOE NO. 101 AND JANE DOE NO. 102'S RESPONSE IN OPPOSITION TO MOTION TO COMPEL AND IDENTIFY JANE DOE NUMBERS 101 AND 102 IN THIRD PART
CASE NO.: 08-CV-8038I-MARRA/JOHNSON EFTA00182748 Case 9:08-cv-80119-KAM Document 152 Entered on FLSD Docket 06/10/2009 Page 2 of 8 Doe 101 v. Epstein Page 2 JANE DOE NO. 6, Plaintiff, JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80994-CIV-MARRA/JOHNSON CASE NO.: 08-80993-CIV-MARRA/JOHNSON JANE
OHNSON Plaintiff, JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFFS JANE DOE NOS. 101 AND 10
v. Epstein Page 4 Defendant, Jeffrey Epstein, ("Mr. Epstein"), by and through his undersigned attorneys, her
ICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN Defendant. JANE DOE NO. 3, Plaintiff,
edia, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and 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 (F
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
cause shown in order to assure a fair 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 wit
Entities connected to both Jeffrey Epstein and Florida Freedom Newspapers.

Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Woody Allen
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Barry Diller
PERSON
Alexander Acosta
PERSONScott Rothstein
PERSONRobert D. Critton
PERSONJack Scarola
PERSONSpencer Kuvin
PERSON
Bill Burns
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Tampa
LOCATIONPalm Beach Lakes Blvd
LOCATION
The Palm Beach Post
ORGANIZATION