Epstein Secrets

Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti

porting exhibit 30 be filed in the public file and docketed as of today's date, as timely filed. DATED: January 21, 2015. Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-28

o sleazy, unprofessional, disbarrable lawyers, Paul Cassell, a former federal judge [and] current professor, and another sleazy lawyer from Florida, Brad Edwards — . .. and said who would fit into this description: A lawyer, who knows Epstein, who helped draft ...? Ha, Dershowitz! So they and the woman got t

is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United St

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

§ 79-h(b), (c).° But the Court need not even consider the scope of the reporter's privilege or if it has been waived. Without relying on an explicit First Amendment, common law or statutory privilege, under Rules 26 and 45, federal courts have nonetheless factored in the burden on First Amendment rights when an

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

§ 79-h(b), (c).° But the Court need not even consider the scope of the reporter's privilege or if it has been waived. Without relying on an explicit First Amendment, common law or statutory privilege, under Rules 26 and 45, federal courts have nonetheless factored in the burden on First Amendment rights when an

as long as such a reading is not plainly contrary to the i intent of Congress. United States X-Citement Video, Inc., 513 U.S. 64, 78 (1994), citing Edward., DeBartolo_ Corp. Florida Gulf Coast Building & Constr. Thades Council, 485 U.S. 568 (1988). At the least, to eliminate questions as to its const

is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United St

onstitutional basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne

gious organizations on federal income tax returns stated cause of action for dis- crimination among religions prohibited by establishment clause of First Amendment. 26 U.S.C.A. § 170; Fed.Rules Civ.Proc. Rule 12(b)(6), 28 U.S.C.A.; U.S.C.A. Conan. Amend. 1. 4. Constitutional Law 4=,84(I) Establishment claus

s long as such a reading is not plainly contrary to the intent of Congress. United States v. X-Citement Video, Inc., 513 U.S. 64, 78 (1994), citing Edward., DeBartolo_ Corp. v. Florida Gulf Coast Building & Constr. Thades Council, 485 U.S. 568 (1988). At the least, to eliminate questions as to its con

is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who 'knowingly' persuade or entice, or attempt to persuade or entice, minors. United S

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

rted not only by the Eleventh Circuit cases cited throughout this pleading but also by the Supreme Court, which upheld a protective order against a First Amendment challenge finding that information learned during the discovery process is not subject to public release in part because of the risk that informati

, as I ng as such a reading is not plainly contrary to the intent of Congress United States X-Citement Video, Inc., 513 U.S. 64, 78 (1994), citing Edward." DeBartolo Corp. Florida GulfCoast Building & Constr. Trades Council, 485 U.S. 568 (1988). At e least, to eliminate questions as to its constitut

is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who ' owingly' persuade or entice, or attempt If to persuade or entice, minors. Unite