Epstein Secrets

Florida, this day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT O

day of , 2009. 1 e v izOOS David French !:)r- c\c"``A- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., EDWARDS, ESQ., Brad Edwards and Associates, , JAY HOWELL, ESQ., Jay Howell & Associates, PA, erbury Goldberger & Weiss, PA., EFTA00722688 IN THE COURT OF THE FIFTEENTH JUD

is day of , 2009SAGOO et -, IREml VA r e `0 • David French' . Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., D EDWARDS, ESQ., Brad Edwards and Associates. , JAY HOWELL, ESQ., Jay Howell & Associates, PA, iterbuly Goldberger & Weiss. P.A. EFTA00722689 g e sz LEOPO

. 353 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00722695 v. Epstein Page 2 10. Buchanan v. Miami Herald Publishing Co., 230 So.2d 9, 12 (Fla. 1969) 11. Baisch v. Gallina, 346 F.3d 366, 373 (2nd Cir. 2003) 12. Fla. Stat. §772.101, et seq., commonly referred to as F

t with a lawyer." [Exhibit 1]. The source for much of that Article's information is Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards. 2. In fact, Mr. Scarola is quoted to have said the following: EFTA00616236 CASE NO. 50 2009 CA 040800 XXXXMB AG a. "We would be very keen to

ew details about Epstein's friendship with Prince Andrew." [Exhibit 2]. 4. Two days later, another British publication, "The Observer," reported: "Edwards' lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince [Andrew] about what he may or may not have

s were made against him by as many as 40 girls, of whom 17 have settled civil claims they brought against the billionaire. Epstein is himself suing Brad Edwards, a lawyer for several of the girls. Epstein alleges that Mr Edwards was linked to a fraud committed by a former colleague — a claim dismissed by the

ol and prohibit such extra- judicial commentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair trial. See State ex. rd. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976). Courts in Florida may take steps to protect against pretrial publicity. See Shepnard v. - 2 - EFTA00

A JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTI

, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs

led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.

o insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. reL Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); Sentinel Commc'n Co. v. Watson, 615 So. 2d 768, 769 (Fla. 5th DCA 1993). The limitations imposed by a

EFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER

, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs

led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.

insure that Mr. Epstein receives a fair trial. See Sheppard v. Maxwell, 384 U.S. 333, 348, 86 S. Ct. 1507, 16 L. Ed. 2d 600 (1966); State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); Sentinel Commc'n - 4 - FOIVLER WHITE BURNER P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14u ,

nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq.

e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Leo (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil

, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton

ce notice is not always required: Unlike the closure of court proceedings, which has been held to require notice and hearing prior to closure, see Miami Herald Publishing Co. v. Lewis, 426 So. 2d 1 (Fla. 1982), the closure of court records has not required prior notice. Requiring prior notice of closure of a court recor

st Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Bo

m Beach, Florida. Hon. Jeffrey Colbath CIRCUIT JUDGE cc: U.S. Attorney's Office State Attorney's Office Jack Alan Goldberger, Esq. Bradley 1. Edwards, Esq. Deanna K. Shullman, Esq. Spencer T. Kuvin, Esq. 2 EFTA00231170 KnEusixn-WALsit, COMPIANI & VARGAS, P.A. SUITE 5O3. FLAGLER CENTER 501

romised in the Crime Victims' Rights Act. DATED this 7th day oil& 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 emu, E

ce notice is not always required: Unlike the closure of court proceedings, which has been held to require notice and hearing prior to closure, see Miami Herald Publishing Co. v. Lewis, 426.. 2d I (Fla. 1982), The closure of court records has not required prior notice. Requiring prior notice of closure of a court record

nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton. Esq.

sed in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar if 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 $0410 EFTA00

, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton

ce notice is not always required: Unlike the closure of court proceedings, which has been held to require notice and hearing prior to closure, see Miami Herald Publishing Co. v. Lewis, 426 So. 2d 1 (Fla. 1982), the closure of court records has not required prior notice. Requiring prior notice of closure of a court recor

s O ) .1 •s--• tAtin Beach, it Our' c C•T David French Vr- Circuit Judge Copies furnished: TTON, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL, ESQ., Jay Howell & Associates, PA.. and JACK A. GOLDBERGER, ESQ., Atterbury Goldberger EFTA0061441

, JR., ESQ., and MICHAEL J. PIKE, ESQ., and BRAD EDWARDS, ESQ., Brad Edwards and Associates, JAY HOWELL,

53 So.2d 547 (Fla. 1977). 9. Snipes v. West Flaciler Kennel Club, 105 So.2d 164 (Fla. 1958) EFTA00614425 • v. Epstein Page 2 10. Buchanan v. Miami Herald Publishing Co., 230 So.2d 9, 12 (Fla. 1969) 11. Baisch v. Gallina, 346 F.3d 366, 373 (2nd Cir. 2003) 12. Fla. Stat. §772.101, et seq., commonly referred to as F

t with a lawyer." [Exhibit I]. The source for much of that Article's information is Jack Scarola, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards. 2. In fact, Mr. Scarola is quoted to have said the following: EFTA00599554 CASE NO, 50 2009 CA 040800 XXXXMI1 AC; a. "We would be very keen t

Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 and Gary Farmer, Esquire, Farmer, Jaffe, Weissing, Edwards, Fistos, et al., 425 N. Andrews Avenue, 42, Fort Lauderdale, FL 33301. J eph Ackerman, Jr. Fla. Bar No. 235954 Christopher E. Knight Fla. Bar.

mmunications between lawyers and/or litigants and the media are permissible for good cause shown in order to assure a fair trial. See $tate ex. rel. Miami Herald Publishing Co. v. Mslntosh 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers. Inc. v, McCrary, 520 So. 2d 32, 35 (Fla. 1988). 7. The Florida

digging up new details about Epstein's friendship with Prince Andrew." Two days later, on March 13, 2011, "The Observer" reported (copy attached): "Edwards' lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince [Andrew] about what he may or may not . hav

commentary in this matter which either: (1) concerns Mr. Epstein's alleged sexual abuse of or being with minor females; or, (2) is injurious to Mr. Bradley Edwards' reputation, consistent with 4.3-6 of the Rules Regulating the Florida Bar. We trust that you will agree to a swift and amicable resolution of this

munications between the media and lawyers and/or litigants are permissible for good cause shown in order to assure a fair trial. See State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers. Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988). The Florida Supr