Epstein Secrets

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

21 of 37 Doe v. Epstein 08-CV80119 Page No. 21 personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sideway, 966 So.2d 895 (Fla. 4th DCA 2008). Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant'

ce, Dave Brannon, Esq .. At or around that same time, Counsel for Jane Does 2-8 provided a copy of the book or journal to counsel for Jane Doe, Mr. Bradley Edwards. Upon learning of Jane Does 2-8's counsel and Jane Doe's counsel coming into possession of the journal or book in the face of a Rule 4 Appeal, the

arties regularly agree, and courts often order, that discovery information will remain private. 13. The request sought herein is reasonable as Mr. Edwards himself in the past has spoken to the media several times as evidenced by his own affidavit attached hereto as Exhibit "C" at paragraphs 14-28. 14

interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway, 966 So.2d 895 (Fla. 4th DCA 2008). The Supreme Court has "consistently held that a person has no legitimate expectation of privacy in i

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

e 21 of 37 Doe v. Epstein 08-CV80119 Page No. 21 personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway. 966 So.2d 895 (Fla. 4th DCA 2008). Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant'

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

interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sklawav, 966 So.2d 895 (Fla. 4th DCA 2008). Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant'

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

interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway, 966 So.2d 895 (Fla. 4th DCA 2008). Accordingly, based on the facts and circumstances of this case, and under applicable law, Defendant'

8-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Suite 2218 6 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Case 9:08-cv-80119-KAM Document 559 Entered on F

interests, the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions. Favalora v. Sidaway, 966 So.2d 895 (Fla. 4 th DCA 2008). The Supreme Court has "consistently held that a person has no legitimate expectation of privacy in