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

( emphasis added), common-law right of access does not extend to information collected through discovery which is not a matter of public record. See Seattle Times Co. v. Rhinehart, 467 U.S. 20, 33,104 S.Ct. 2199, 2207, 81 L.Ed.2d 17 (1984); Anderson, 799 F.2d at 1441; United States v. Gurney. 558 F.2d 1202, 1209

as alleged, was almost unspeakable." App. p 569. Plaintiff's counsel piled on, offering their own opinions about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator" of Epstein's crimes who "started the whole thing." App. p 569. And Sigrid McCawley praised the pro

about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator"

2 (2d Cir. 1994) Press-Enter. Co. a Superior Ct., 464 U.S. 501 (1984) S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) passim 34 37 passim Seattle Times Co. v. Rhinehart, 467 U.S. 20 (1984) 24 State a Cady, 414 P.3d 974 (Utah Ct. App. 2018) 19 United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) ("Amod

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

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. v. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may re

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

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may rest

ent from counsel. See Composite Exhibit 4. In a parallel article published in the Daily Business Review, Plaintiffs' counsel was quoted as follows: "Edwards said the -10- EFTA00605760 documents at this point will be disclosed only to the plaintiffs and will not become part of the public record." Id. (

out its contents." Tillman v. C.R. Bard, Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 2014 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the dissemination and use of pretrial discovery is particularly important since "[t]he

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

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. v. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has Arepeatedly acknowledged the private nature of discovery@ and that A[a] court may re