Epstein Secrets

lbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "l

This Improper 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

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

lsouth.net Counsel for Defendant Jeffrey Estein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos &

3401-5012 561-659-8300 Fax: 561-835-8691 i [email protected] Counsel for Defendant Jeffrey Estein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] Co

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to piggyback on DE 462 (a similar order), and thus seems to hone in on the "required records" exception f

nfra, the federal government provided Epstein with the NPA and the list attached thereto. The NPA is now a public document and the list, pursuant to Brad Edward's Agreement with Judge I. Colbath, remains confidential. 2 FRE 410(4) is particularly directed to communications in matters which, like Epstein's, di

y transmit passenger and crew manifest information for all flights arriving into and/or departing out of the United States. As this court knows, Mr. Edwards has conducted extensive discovery, has questioned individuals as to whether Epstein owns private aircraft and has obtained certain flight manifests

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v, Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

Esq. Searcy Denney Scarola Barnhart & Shipley, Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment

rst Orseck, P.A. 25 West Flagler Street, Suite 800 Miami, FL 33130 305 358-2800 Fax: 305 358-2382 [email protected] [email protected] Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 9

antial and 'real,' and not merely trifling or imaginary, hazard[] of incrimination" when it comes to Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). (i) The Fifth Amendment and Plaintiffs' Rule 4 Appeal The Fifth Amendment serves as a guarantee against testimonial com

ey Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 [email protected] Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwar

he claimant must [also] be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, responses to the requests propounded upon Epstein would provide information which is protected by the privi

the NP A is a list which delineates alleged victims. Once the NP A 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 Number IO seeks information that may vio

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

ocket 10/16/2009 Page 4 of 6 CASE NO: 08-CV-80119-MARRA/JOHNSON 5 DATED October 16, 2009 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Flo

minal nature, such as threats of liability in civil suits.’” United States v. Conces, 507 F.3d 1028, 1040 (6th Cir. 2007) (quoting United States v. Apfelbaum, 445 U.S. 115, 125 (1980)). It is Epstein’s burden to “demonstrate a real danger of incrimination if he were to respond to any particular discover

th Avenue North Suite 404 Lake Worth, FL 33461 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s

uart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone:954-522-3456 Fax: 954-527-8663 bedward

7)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, for these reasons, Epstein's objections to the Magistrate's Order should be sustained, and this Court shoul