Epstein Secrets

-Filed 11/23/2015 05:53:31 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWI

ASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ’S MOTION TO DETERMINE CONFIDENTIALITY OF COURT RECORDS Plaintiffs/Counterclaim Defendants Bradley J. Edwards an

ous adult when she flew on that airplane. Q. You were asked on the occasion of that same Don Lemon CNN interview what possible motive the attorneys, Brad Edwards and Paul Cassell, could have had to have identified you in the pleading that was filed in the Crime Victim's Rights Act case. _ warn nw be wn Bb N

GRAL TO THIS DEFAMATION CASE. In his motion, Dershowitz never recounts the heavy burden that he must carry to seal the records at issue. To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing of “confidential” materials. But the Rule begins by recounting the overarching principle that “t]he public shall have access t

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

victims and the public," Berger said. "The public should be outraged it has gone as far as it has." A second attorney representing the women, Brad Edwards, has seen the sealed document A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the wom

he women, Brad Edwards, has seen the sealed document A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the women were "outraged" at what had been negotiated without their knowledge. A reporter asked Edwards if he thought Epstein re- ceived

endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of M., Assistant State Attorney Barbara Burns was present-on behalf-of-the

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00231347 2 1 ON BEHAL

fendant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

Critton, Esq. were present on behalf of Jeffrey Epstein. Ms. Shullman, Esq. was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of M., Mr. Kuvin, Esq. was present on behalf of Assistant State-Attorney Barbara Burns-was present on behalf-of-the Sta

o & Bralow 101 N.E. 3rd Avenue - Ste 1500 22 Fort Lauderdale, Florida 33301 23 ON BEHALF OF EW, THE INTERVENER: WILLIAM J. BERGER, ESQUIRE 24 BRAD EDWARDS, ESQUIRE 225 NE Mizner Blvd Ste 675 25 Boca Raton, Florida 33432 SUSAN WIGGINS, R.P.R. AND OFFICIAL COURT REPORTER EFTA00232467 2 1 ON BEHAL

endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu

, State Attorney's Office- West Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 4 Shullman, Robert D. Critton, BURMAN, CRITTON, LUTTIER, & COLEMAN, . this 11 day of June, 2009. Deanna K. B

e women, Brad Edwards, has seen the sealed document. A federal judge allowed him and his clients to view it, but not to discuss its con- tents. Edwards said the women were "outraged" at what had been negotiated without their knowledge. A reporter asked Edwards if he thought Epstein re- ceived

iam J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 4 Shullman, Rober

endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu

rd, Suite 200, Palm Beach Gardens, FL 33410; and Bradley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rosenfeldt

00, Palm Beach Gardens, FL 33410; and Bradley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rose

n response to Florida media reports of hidden cases and secret dockets, a process that has come to be known as "super-sealing." In re Amendments to Florida Rule of Judicial Administration 2.420, 954 So. 2d 16 (Fla. 2007). In adopting the interim rule, the Florida Supreme Court confirmed its commitment to safeguarding the public's constitut

of the June 12, 2009 hearing on Mr. Epstein's renewed motion to stay the civil cases pending in front of federal Judge Marra, Jane Doe's attorney, Brad Edwards, also counsel for respondent E.W., advised Judge Marra that he had filed the non-prosecution agreement "under seal in your court" in "Jane Doe 1 an

eement "under seal in your court" in "Jane Doe 1 and 2 vs. United States of America" (EWA at 5). Mr. Epstein's counsel advised Judge Colbath of Mr. Edwards' sealed filing in federal court at the June 25, 2009 hearing: "June 12th, Mr. Edwards advised Judge Marra that he had, in fact, filed a nonprosecut

on agreement and addendum is not a public record. It is confidential by its terms and did not become a public record when it was filed under seal. Florida Rule of Judicial Administration 2.420 governs the disclosure of judicial records. See Morris Publ'g Group, LLC v. State, 34 Fla. L. Weekly D1101 (Fla. 1st DCA June 1, 2009). Under rule

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

uite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las

nt MOTION TO MAKE COURT RECORDS CONFIDENTIAL •1 r Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu

as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B

uite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las

fendant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to beat as confidential the following records. A. A docum

ed 12/11/2015 05:54:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE 15-000072 EDWARDS, et at, Plaintiffs / Counterclaim Defendants, vs. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S OPPOSITION TO

motion to file under seal allegations that had been stricken by the United States District Court for the Southern District of Florida: To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing of "confidential" materials. But the Rule begins by recounting the overarching principle that "[t]he public shall have acces