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d infra, Mr. Edwards has certain info1mation from the Palm Beach Police Department, which resulted from various alleged
, the Mermelstein and Horowitz firm was quoted in the Palm Beach Post stating, among other things, that the book sold t
18 Doe v. Epstein 08-CV80119 Page No. 10 2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4th
fs' allegations are without any factual basis and know such assertions to be false and untrue. 3. Defendant agrees with Plaintiff's assertion that the Palm Beach Police Department (PBPD) executed a search warrant at EPSTEIN's Palm Beach mansion on October 25, 2005. See '1!4 Plaintiffs' motion. 4. Defendant's atto
tion where a litigant or witness is being asked to provide information or respond to a question that may incriminate him in a crime. See generally, DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4 th DCA 1983). The privilege against self-incrimination may be asserted during discovery when a litig
rmation from both the Palm Beach Police Department and the State Attorneys' file. In fact, as argued infra, Mr. Edwards has certain information from the Palm Beach Police Department, which resulted from various alleged "trash pulls" from a residence on Palm Beach (e.g., certain notepads). Finally, at the deposition
n den; the occurrence of the assaults alleged and still maintain the safe harbor of the 5 Amendment.2 See Ohio v. Reiner, 532 U.S. 17(1991). 2 See DeLisi v. Bankers Ins. Company. 436 So.2d 1099 (Fla. 4th DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Cl
UIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION STATE OF FLORIDA vs. Case Nos.: 2006-CF9454-AXX & 2008-9381U-AND( JEFFREY EPSTEIN PALM BEACH POST'S MOTION TO INTERVENE AND PETITION FOR ACCESS Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post (the "Post") moves to Intervene in this action
thout knowledge and deny. 2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 41" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination C
oid giving discovery, using the fifth amendment as both a ‘sword and a shield.” DePalma v. DePalma, 538 So. 2d 1290, 1290 (Fla. 4th DCA 1989)(quoting DeLisi v. Bankers Insurance Co., 436 So. 2d 1099 (Fla. 4th DCA 1983)). Put another way, “[a] civil litigant’s fifth amendment right to avoid self-incriminat
Page: HOUSE_OVERSIGHT_013316 →questioning so savage that it made local headlines. See Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts Used Against Them, Palm Beach Post News, Jan. 23, 2010, available at pasts-192988.html attached hereto as Exhibit “LL.” Edwards Pursues Other Lines of Discover 69. Because of Epstein’s th
Page: HOUSE_OVERSIGHT_013345 →Entities connected to both The Palm Beach Post and DeLisi

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Palm Beach
LOCATION
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Alexander Acosta
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Donald Trump
PERSONthe Southern District
LOCATIONScott Rothstein
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Alfredo Rodriguez
PERSONJoe Recarey
PERSONMaria Farmer
PERSON
Sarah Kellen
PERSON