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to 29 Response in Opposition to Motion to Unseal Non-Prosecution Agreement filed by Jane Doe. (Attachments: # 1 Exhibit October 9, 2008 letter from Brad Edwards, Esquire to AUSA Dexter Lee, # 2 Exhibit October 15, 2008 Letter from Brad Edwards, Esquire to AUSA Dexter Lee)(Edwards, Bradley) (Entered: 10/16/20
nt to the victims included this proposed stipulation: On July 9, 2008, AUSA Villafafla sent a victim notification to Jane Doe # I via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia Declaration. That notification contains a written explanation of the full terms of the agreement
JUDGE 14 Appearances: 15 FOR THE PETITIONER Bradley J. Edwards, ESQ., and 16 Paul G. Cassell, ESQ. 1? FOR THE RESP
s based in the Lewis & Clark College of Law. During the call, Ms. Garvin was not advised about the Non-Prosecution Agreement. In mid-June 2008, Mr. Edwards contacted Assistant U.S. Attorney Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. Edwards asked to meet to pro
the improper deposition. 12. In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform her that he
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11ffi Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as
nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq.
e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Leo (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil
, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton
e causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc.,. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA (noting-Government's representation-to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein while Jeffrey
HSTEINSPOStotroL,u Aln-dit Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone Telecopier By. Bradley I. Edwards Florida Bar Non= William UBerger Florida ar N . 3 EFTA00232414 • p ro v k i? J IN me cRIMINAI. DI% 'SION OP u I . dui r RT OF TI If!
uite 400 West Palm Beach, Florida 33401 s/ Brad Edwards Brad Edwards, Esquire Attorney for Petitioner
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
s of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00215846 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 4 of 7 5.) F
to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA0
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11'h Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
s of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00215943 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 4 of 7 5.) F
to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA0
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11'h Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
s of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00235149 Case 9:08-cv-80736-KAM Document 29 Entered on FLSD Docket 10/08/2008 Page 4 of 7 5.) F
to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA0
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. I. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
s of those signed acknowledgements to abide by the Protective Order were then to be provided "promptly" to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA00235318 5.) First, there is no sealing order. Second, the Protective Order does not prevent petit
to the United States. To date, only Attorney Brad Edwards has provided a signed acknowledgement. 3 EFTA0
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising, Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as a
08 Page 8 of 8 Ann Marie C. ViBefana, AUSA United States Attorneys Office 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 al Brad Edwards • • U U ll Brad Edwards, Esquire Attorney for Petitioner Florida Bar No. 542075 I HEREBY FURTHER CERTIFY that on September 25, 2008, a true a
e description of another feature of the non- U U U U prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad . . Edwards, Esq. to AUSA Dexter Lee (rioting Government's representation to victims of a right to recover at least 5150,000 in damages from Jeffrey Epstein whi
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising. Inc. v. City of Clearwater. Fla. 351 F.3d 1112, 1116 (11h Cir. 2003). Petitioners already have obtained access to the agreement, so they cannot claim a denial of access as an
ve provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct 15, 2008 Letter from Brad Edwards, Esq, to AUSA (noting Goverament-s represen ' teflon to victims of atight to recover at least $150,000 in damages from Jeffrey Epstein while Jeff
Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: s/ Brad Edwards Brad Ed
causal conduct; and (3) a likelihood that the injury will be redressed by a favorable decision. Granite State Outdoor Advertising. Inc. v. City of Clearwater, Fla., 351 F.3d 1112, 1116 (11th Cir. 2003). Petitioners already have obtained access to the agreement,, they cannot claim a denial of access as an
/24/2014 - 04/27/2016) 6. Moore, Aixa it Associated with Other Companies - MEMBER (03/31/2008 - 04/27/2016) - MANAGER (12/012003) 7. Mullally, Edward R / Moderate Risk - PRESIDENT (03/31/2008 - 04/27/2016) - OWNER (02/1998) Inco • oration/SOS 2 active, 1 other NO. NAME FILING TYPE STATUS F
each, FL 32266-5251 Duval County Jacksonville, FL 3. 6601 Blackfin Way Apollo Beach, FL 33572-3029 Hillsborough County Tampa-St. Petersburg- Clearwater, FL 727-943-5805 4. (Most Recent Listing) 07/012013.06/132017 8 (Business) 813-645-6815 tid (Most Recent Listing) Of/01/2014 - 06/ t 32017 @
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