Epstein Secrets

The Palm Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger of Rothstein Rosenfeldt Adler have filed a similar motion on behalf of a non-party known as =11 and that a motion is set for he

• •••••••• ••••••••••••••• • To: R. Alexander Acosta, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq, Jack Alan Goldberger, Esq. Brad ley J. Edwards, Esq. William J. Berger, Esq. From: Deanna K. Shullman, Esq. Date: 06/01/2009 Re: State v. J. Epstein Pages: 6 Urgent U For review U I Pl

el for Plaintiff in Related Case No. 80811 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

hael McAuliffe, Esq. Jack Alan Coldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: »minne K. Shullm

l conduct or predisposition in civil cases, which will be continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the rationale of Rule 412, however, courts should enter appropriate orders pursuant to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and to ensu

STOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for

fer facts to a jury, statements to a jury, that they are going to be then arguing are credible, and so we have this joinder motion, drafted by Mr. Edwards and Mr. Cassell, that they would like to introduce into evidence, whole cloth into evidence, that contains the legal arguments and the statements o

there's an additional argument from counsel. It was their motion, so if it is, then -- THE COURT: Yes. Okay. MR. EDWARDS: And by the way, this is Brad Edwards on behalf of Ms. but I believe it's their up. MS. MENNINGER: Your Honor, a couple more points. They are related to what was just articulated for

22 23 24 25 problem. Well, no, it isn't. No, it isn't. Okay. So let's do 675. MS. MENNINGER: Your Honor, I will say that it is my reading of Rule 412 that any hearing that is based upon in part Rule 412 is supposed to be conducted in a in camera setting. MS. SCHULTZ: Counsel for Ms. has no objec

ERVICE LIST DOE vs. JEFFREY EPSTEIN United States District Court, Southern District of Florida Jack Alan Goldber er Es . Robert D. Critton, Es . Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsberg

r er Es . Robert D. Critton, Es . Bradley James Edwards Isidro Manuel Garcia Jack Patrick Hill Katheri

9-KAM Document 266 Entered on FLSD Docket 08/14/2009 Page 7 of 9 history, thereby evading the limitations on discovery and admissibility found in Rule 412 for the only conceivable purpose of harassing the Plaintiff. Defendant asserts that he seeks to use investigators to ask ex-boyfriends and friends

ility to know all of the public 4 information that would tell her this is factually true. 5 THE COURT: But that's not -- okay. All right. 6 MR. EDWARDS: She can definitely -- 7 THE COURT: It doesn't wash. You know it doesn't 8 wash. You must know it doesn't wash. 9 MR. EDWARDS: I'm not saying sh

same 2 problem. Well, no, it isn't. No, it isn't. 3 Okay. So let's do 675. 4 MS. MENNINGER: Your Honor, I will say that it is my 5 reading of Rule 412 that any hearing that is based upon in part 6 Rule 412 is supposed to be conducted in a in camera setting. 7 MS. SCHULTZ: Counsel for Ms. has no