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This Improver Motion Practice And Have No Demonstrable Need For More Several depositions have occurred over the last 4 weeks wherein it appears Mr. Edwards already has the information he seeks responsive to these requests, which is likely the reason Mr. Edwards has not filed any affidavits supporting t
ached to the NPA is a list which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information th
of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. aLL, tl,g Goodyear Tire & Rubber Co. v. Chiles Power Stumlva Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to se
ERVICE LIST Jane Does 1 and 2 1. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. Quinney College of Law at the University of Utah II= Attorneys for Jan
istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr
hapter." 18 U.S.C. § 3771(d)( I). 5 EFTA00211517 procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. I. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit went further, finding that settlement communications were privileged a
rsons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923
& Health Plans, 16 F.Supp.2d 1164 (C.D.CaI. 1998) 33, 37, 40 Gill v. Gulfstream Park Racing Ass 'Ft, Inc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v.
Entities connected to both Bradley Edwards and Goodyear Tire & Rubber Co.

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONMaria Farmer
PERSON
George W. Bush
PERSON
United States
LOCATIONSouthern District
LOCATIONRobert D. Critton
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONMichael J. Pike
PERSONMartin Weinberg
PERSONSpencer Kuvin
PERSONRoy Black
PERSON
Jay Lefkowitz
PERSON
George Mitchell
PERSON
Harvey Weinstein
PERSON