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ce, Dave Brannon, Esq .. At or around that same time, Counsel for Jane Does 2-8 provided a copy of the book or journal to counsel for Jane Doe, Mr. Bradley Edwards. Upon learning of Jane Does 2-8's counsel and Jane Doe's counsel coming into possession of the journal or book in the face of a Rule 4 Appeal, the
arties regularly agree, and courts often order, that discovery information will remain private. 13. The request sought herein is reasonable as Mr. Edwards himself in the past has spoken to the media several times as evidenced by his own affidavit attached hereto as Exhibit "C" at paragraphs 14-28. 14
ess. See Seattle Times Co. v. Rhinehart, 467 U.S. at 32-34, (pretrial interrogatories and depositions "were not open to the public at common law"); Gannett Co. v. DePasguale, 443 U.S. 368, 396, 99 S.Ct. 2898, 2914, 61 L.Ed.2d 608 (1979) (Burger, C.J., concurring) ("[I]t has never occurred to anyone, so far
ice, Dave Brannon, Esq.. At or around that same time, Counsel for Jane Does 2-8 provided a copy of the book or journal to counsel for Jane Doe, Mr. Bradley Edwards. Upon learning of Jane Does 2-8's counsel and Jane Doe's counsel coming into possession of the journal or book in the face of a Rule 4 Appeal, the
ies regularly agree, and courts often order, that discovery information will remain private. -1-213. The request sought herein is reasonable as Mr. Edwards himself in the vast has spoken to the media several times as evidenced by his own affidavit attached hereto as Exhibit "C" at paragraphs 14-28. 14
ess. See Seattle Times Co. v. Rhinehart, 467 U.S. at 32-34, (pretrial interrogatories and depositions "were not open to the public at common law"); Gannett Co. v. DePasquale 443 U.S. 368, 396, 99 S.Ct. 2898, 2914, 61 L.Ed.2d 608 (1979) (Burger, C.J., concurring) ("[I]t has never occurred to anyone, so far
tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr
Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. on au er a e, on a Paul G. Cassell S.J. Quinney College of Law at the Universit of Utah Salt Lake Cit Utah 84112 Attorn
fied a common law tradition of public access to criminal trials, this never extended to preindictment, pretrial proceedings involving a grand jury. Gannett Co. 443 U.S. 368, 99 S.Ct. 2898, indicates as much. In any event, even if there was once a common law right of access to materials of the sort at issue
h Epstein!' Ms. McCawley echoed Mr. Boies, saying that, "The pain [Maxwell] has caused will never go away but today is a step toward healing." Id. Bradley Edwards, another attorney representing witnesses in this matter made similar presumptively prejudicial statements following Ms. Maxwell's arrest:5 'The real
but today is a step toward healing." Id. Bradley Edwards, another attorney representing witnesses in this
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
but today is a step toward healing." Id. Bradley Edwards, another attorney representing witnesses in this
h Epstein!' Ms. McCawley echoed Mr. Boies, saying that, "The pain [Maxwell] has caused will never go away but today is a step toward healing." Id. Bradley Edwards, another attorney representing witnesses in this matter made similar presumptively prejudicial statements following Ms. Maxwell's arrest:5 'The real
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
truth, as alleged, was almost unspeakable." M Plaintiff's counsel piled on, offering their own opinions about Ms. Maxwell's guilt. For example, Mr. Edwards opined that Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing." M Ms. McCawley praised the prosecutors: "[T
h Epstein!' Ms. McCawley echoed Mr. Boies, saying that, "The pain [Maxwell] has caused will never go away but today is a step toward healing." Id. Bradley Edwards, another attorney representing witnesses in this matter made similar presumptively prejudicial statements following Ms. Maxwell's arrest:5 `The real
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
Entities connected to both Bradley Edwards and Gannett Co.

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATIONMichael J. Pike
PERSON
Department of Justice
ORGANIZATION
Adam D. Horowitz
PERSON
Bill Clinton
PERSONIsidro Manuel Garcia
PERSON
Weissing
PERSON
the University of Utah
ORGANIZATION