Epstein Secrets

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

ntial information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 7. Moreover, the right to privacy encompasses at least two different kinds of interests, the individual

8-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 6 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Case 9:08-cv-80119-KAM Document 559 Entered on F

ntial information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 8. If disclosure is made, this court should then determine what portions of the "book" or "journal" shoul

Lake City, Utah 84114; [email protected] to: Bradley J. Edwards, Esq, Farmer, Jaffe et al, 425 North Andrews Aven

BREAK --- BACKGROUND The underlying action before this Court is a defamation case filed by a former federal judge, Paul Cassell, and his colleague Brad Edwards, who represent various sexual trafficking victims in a case pending in the Southern District of Florida, specifically case no. 08-cv-80736- KAM, here

tirety because on its face it seeks solely privileged and confidential information relating to her retention of BSF.* See Westco Inc. v. Scott Lewis’ Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4™ DCA 2010) (court explaining that “[w]hen confidential information is sought from a non-party, the trial court must deter