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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
derlying Rule 408 are essentially the same as those underlying Fed. R. Crim, P. 11 (f) and 410: "to encourage non- litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th Cir. 1976). See, Lls·, Stockman v. Oakcrest Dental Center, P.C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose
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
purposes underlying Rule 408 are essentially the same as those underlying Rules ll(f) and 410: "to encourage non-litigious solutions to disputes." Reichenbach v. Smith, 528 F.2d 1072, 1074 (I Ith Cir. 1976). See, M-, Stockman v. Oakcrest Dental Center, P. C., 480 F.3d 791, 805 (6th Cir. 2007)("the purpose
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
cial efficiency it fosters is lost. Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003)(emphasis added)! See Reichenbach v. Smith, 528 F.2d 1072, 1074 (11th The Federal Circuit declined to recognize a settlement negotiation privilege in In re MTSG, Inc., 675 F.3d 1337
Entities connected to both Bradley Edwards and Reichenbach

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONMaria Farmer
PERSON
United States
LOCATION
Salt Lake City
LOCATION
Adam D. Horowitz
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSONSpencer Kuvin
PERSON
Jay Lefkowitz
PERSONMermelstein & Horowitz
ORGANIZATION
Harvey Weinstein
PERSON
Bradley Cooper
PERSON
Supreme Court
ORGANIZATION
Harry Reid
PERSON
Justin Trudeau
PERSON
Jes Staley
PERSON