Epstein Secrets

cts were needed. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidenc

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

EFTA00208033 Case 9:08-cv-80736-KAM Document 75 Entered on FLSD Docket 05)02'2011 Page 11 of 12 DATED: May 2. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jan

tates.. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock'. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside t

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

ates v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside

urt should deny the defense attorneys' motion to intervene in this Crime Victims' Rights Act case.' DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice A

s Crime Victims' Rights Act case.' DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. E-mail: [email protected] and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jane Doe #2 4 The defense

even applies. In any event, it is obvious that grand jury secrecy only extends to matters that occurred in secret before the grand jury. See, e.g., Blalock. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

ings in this matter, except for the portions that the victims have agreed should remain under seal. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el •

e agreed should remain under seal. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 'ICAtT 1. A • ^I and Paul G. Cassell Pro Hac Vice ir% T el • !I If Attorneys for Jane Doe #1 and Jane Doe #2 8

Statest Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock' United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

ngs: the 1987 murders of David Knobling and Robin Edwards, and the 1989 slaying of Teresa Howell. Cathy Th

), Newsweek (11/15, Higham), New York Daily News (11/15, Schladebeck), New York Post (11/15, Donlevy), New York Times (11/15, Coleman), NTD (11/15, Blalock), Patch (11/15, IJssner), People (11/15, Sheffield), Politico (11/15, Svirnovskiy), USA Today (11/15, Mansfield), and Washington Examiner. Trump Pa

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

Ex pane Jones County Grand Jury, First Judicial Dist., 705 So. 2d 1308 (Miss. 1997). [F1436) Kent I. Benson, 945 F.2d 372 (11th Cir. 1990. [F1437) Blalock LU.S., refill; denied, 856 F.2d 200 (11th Cr. 1988) and (distingured by, estin McDaniel, 760 F. Supp. 1563 (M.D. Ga. 1991)) and (disagreed with o