Epstein Secrets

have counsel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good

sel state their appearances? MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs Jane 2 through Jane Doe 7. THE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. : Good morning, Your Honor. Sid for Jane Doe II. THE COURT: Good morning. MR.

ard Miami, FL 33160 305.931.2200 For Jane Doe BRADLEY J. EDWARDS, ESQ. 17 Rothstein Rosenfeldt Adler 401 East Las Ola

obtain the "extraordinary" remedy of a stay is inevitably much reduced. Sterling Nat'l Bank, 175 F. Supp. 2d at 577 (internal citations omitted). The First Circuit has noted that the decision whether to grant a stay "is highly nuanced ... [and] involves competing interests. Balancing these interests is a situat

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

gned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a company may maintain even its attorney-client privilege and work-product privilege in materials that it discloses to the U.S. Attor

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

gned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a company may maintain even its attorney-client privilege and work-product privilege in materials that it discloses to the U.S. Attor

SERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC Hollywood, Florida 33020 Paul G. Cassell S.J. Quinney College of Law at the Salt Lake C

istrict Court, Southern District of Florida Brad Edwards, Esq., The Law Offices of Brad Edwards & Associa

plea or sentence only if . . . (B) the victim petitions the court of appeals for a writ of mandamus within 14 days . . ." 18 U.S.C. § 3771(d)(5). The First Circuit addressed how the conflict between the rights of victims and defendants is exacerbated by the passage of time in United States v. Aguirre-Gonzalez ,

about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator"

Document 10-1, 07/30/2020, 2896538, Page14 of 38 Plaintiff's counsel piled on, offering their own opinions about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator" of Epstein's crimes who "started the whole thing." Id. And Sigrid McCawley praised the prosecutors

rder requiring disclosure to the Providence Journal of various documents reflecting the results of an unauthorized and illegal wiretap. Id. at 889. The First Circuit explained that litigants are entitled to meaningful appellate review, which demands the opportunity for the appellate court to "take a fresh look a

e Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim

016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At

ess: Certainly it is one thing to revive a prosecution already dead, and another to give it a longer lease of life. The question turns upon how 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section

ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe

how much violence is done to our instinctive feelings of justice and fair play. For the state to assure a man that he has become safe from its 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section

ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe

how much violence is done to our instinctive feelings of justice and fair play. For the state to assure a man that he has become safe from its 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section

1) Doe No. 1. v. United States, 32, 104 33 86 749 F.3d 999 (11th Cir. 2014) 117, 118, 119 Dowling v. United States, 493 U.S. 342 (1990) 52 Edwards v. Mazzuca, No 00 Civ. 2290 (RIS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 155 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 34 Falter,

ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

shonest. But, while the chase is on, it does not shock us to have it extended beyond the time first set, or, if it does, the stake forgives it. 16 The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim, and declined to reach the issue of whether Section

ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At t

ess: Certainly it is one thing to revive a prosecution already dead, and another to give it a longer lease of life. The question turns upon how to The First Circuit has similarly considered this issue in the context of an ineffective assistance of counsel claim and declined to reach the issue of whether Section