Epstein Secrets

11/09/2009 Page 4 of 26 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite

Notary P\lblic, State of Florida ~squire Deposition Sc1·vices West Po.l1n Bench Of(ice Job ~127542 2 APPEARANCES: On behalf of the Plaintiff: BRADLEY J. EDWARDS, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 401 East Las Olas Boulevard Suite 1660 Fort Lauderdale, Florida 33394 On behalf of the Defendant: ROBERT

CRITTON: Let me put on there, for the -- 12 lf this deposition ls not typed - and We request 13 ii - I'd like at least this portion where 14 Mr. Edwards' last question back about five pages 15 worth, so Just if you could mark it from this 16 page back about five pages. l 7 If nobody requests the

the information requested is neither relevant F to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 13. As illustrated above, the questions are simply not germane to any pending '--.. claim

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

7 of 11 infonnation requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence," citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 10. Accordingly, consistent with counsels' agreement noted above, a protective order shou

ice, 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

ies regularly agree, and courts often order, that discovery information will remain private. -1-213. The request sought herein is reasonable as Mr. Edwards himself in the vast has spoken to the media several times as evidenced by his own affidavit attached hereto as Exhibit "C" at paragraphs 14-28. 14

that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence " chin Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)). 940. Accordingly, consistent with counsels' agreement noted above, a protective order shou