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A JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTI
, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs
led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.
cretion to control and prohibit such extrajudicial commentary and pretrial publicity in order to insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. reL Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (
EFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER
, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs
led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.
cretion to control and prohibit such extrajudicial commentary and pretrial publicity in order to insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910
t with a lawyer." [Exhibit I]. The source for much of that Article's information is Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards. 2. In fact, Mr. Scarola is quoted to have said the following: EFTA00599554 CASE NO, 50 2009 CA 040800 XXXXMI1 AC; a. "We would be very keen t
Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 and Gary Farmer, Esquire, Farmer, Jaffe, Weissing, Edwards, Fistos, et al., 425 N. Andrews Avenue, 42, Fort Lauderdale, FL 33301. J eph Ackerman, Jr. Fla. Bar No. 235954 Christopher E. Knight Fla. Bar.
Miami Herald Publishing Co, v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976). Cowls in Florida may take steps to protect against pretrial publicity. See Sheppard v - 2 - EFTA00599555 CASE NO. 50 2009 CA 040800 X:OO:MB AQ Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 161. Ed. 2d 600 (1966); Sentinel Communic
digging up new details about Epstein's friendship with Prince Andrew." Two days later, on March 13, 2011, "The Observer" reported (copy attached): "Edwards' lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince [Andrew] about what he may or may not . hav
commentary in this matter which either: (1) concerns Mr. Epstein's alleged sexual abuse of or being with minor females; or, (2) is injurious to Mr. Bradley Edwards' reputation, consistent with 4.3-6 of the Rules Regulating the Florida Bar. We trust that you will agree to a swift and amicable resolution of this
ubstantial and imminent threat to a fair trial in Epstein v. Edwards. In Florida, a court may take steps to protect against pretrial publicity. See Sheppard v. Maxwell, 384 U.S. 333, 348 (1966); Sentinel Communications Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by the
they wanted a little good press, as well they should. Take her down and embarrass the hell out of her. It's what she deserves." In another example, Brad Edwards, counsel to numerous accusers, changed the subtitle of his book Relentless Pursuit after Ms. Maxwell's arrest from "My fight for the victims of Jef
t's what she deserves." In another example, Brad Edwards, counsel to numerous accusers, changed the subtit
witnesses. The "circus atmosphere" and "hostile" press that led to a reversal in the Sam Sheppard case are no match for what is occurring here. See Sheppard v. Maxwell, 384 U.S. 333 (1966) (reversing conviction based on hostile television and radio reporting of case: "Given the pervasiveness of modern c
they wanted a little good press, as well they should. Take her down and embarrass the hell out of her. It's what she deserves." In another example, Brad Edwards, counsel to numerous accusers, changed the subtitle of his book Relentless Pursuit after Ms. Maxwell's arrest from "My fight for the victims of Jef
t's what she deserves." In another example, Brad Edwards, counsel to numerous accusers, changed the subtit
witnesses. The "circus atmosphere" and "hostile" press that led to a reversal in the Sam Sheppard case are no match for what is occurring here. See Sheppard v. Maxwell, 384 U.S. 333 (1966) (reversing conviction based on hostile television and radio reporting of case: "Given the pervasiveness of modern c
Palm Beach EFTA00616232 Jack Scarola, Esq. March 15, 2011 Page 2 On March 13, 2011, two days later, "The Observer" reported (copy attached): "Edwards' lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince [Andrew] about what he may or may not have
ubstantial and imminent threat to a fair trial in Epstein v. Edwards. In Florida, a court may take steps to protect against pretrial publicity. See Sheppard v. Maxwell, 384 U.S. 333, 348 (1966); Sentinel Communications Co. v. Watson 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by the
onstitutional basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne
id not offer or advise Shep- pard of other railroad employment upon his release following the change in A&EC ownership. Soon after his dis- charge, Sheppard learned from an inde- pendent source of an open job as spike puller with an A&EC labor gang out of Morehead City. lie had worked out of New Bern w
Entities connected to both Bradley Edwards and Sheppard

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Weissing
PERSONFISTOS & LEHRMAN
ORGANIZATIONDarren Indyke
PERSON
Marc Rich
PERSON