Epstein Secrets

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

1986). Thus, while the public may enjoy the right of access to "pleadings, docket entries, orders, affidavits or depositions duly.filed," Wilson v. American Motors Corp., 759 F.2d 1568, 569 (11 th Cir. 1985) ( emphasis added), common-law right of access does not extend to information collected through discovery whic

orldwide media for dissemination. We have seen similar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, through his counsel, filed a motion for summary judgment along with a statement of facts that was appended as an exhibit. The statement of facts it

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown v. Advantage Eng I, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson v. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

orldwide media for dissemination. We have seen similar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, through his counsel, filed a motion for summary judgment along with a statement of facts that was appended as an exhibit. The statement of facts it

EQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS `GOOD CAUSE' Citing Brown I. Advantage Eng g, Inc., 960 F.2d 1013 (11th Cir. 1992), and Wilson I. American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth "the extraordinary circumstances or particularized needs necessitating a

worldwide media for dissemination. We have seen similar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs= lawyers, Mr. Edwards, through his counsel, filed a motion for summary judgment along with a statement of facts that was appended as an exhibit. The statement of facts

REQUEST FOR A PROTECTIVE CONFIDENTIALITY ORDER IS >GOOD CAUSE= Citing Brown v. Advantage Eng=g, Inc, 960 F.2d 1013 (11th Cir. 1992), and Wilson v American Motors Corp., 759 F.2d 1568 (11th Cir. 1985), the Court has requested that we set forth Athe extraordinary circumstances or particularized needs necessitating a