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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
without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the sh
DANIELS,LESLIE B KOCH,DAVID H PALM BEACH RESORT JACOBS,ANTHONY SAY HEY LLC K
Y MCINTOSH,HENRY BOOMHOWER,R FIGUEROA,BARBARA GOLDSMITH,GERALD C BAKER,HO
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
equesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include speci
facts to back it up. Let's talk about the nonprosecution agreement. It is absolutely factual, Ms. Maxwell was never, not once, ever, contacted by the Palm Beach Police in reference to this investigation. She was never, not once, contacted by the FBI or the U.S. Attorney's Office in reference to this investigation
strich's case, as her fiancé; in Tony Figueroa's case, as her boyfriend. We would ask that the evidence related to the Eppinger materials, Ostrich, Figueroa, and these two police incidents, be admitted at trial. THE COURT: As to Ostrich, did I understand correctly that what you want to present there is
criminal activity came to light when stepmother learned of a fight between and a friend at school over $300 cash found in purse. cooperated with the Palm Beach Police and made recorded telephone calls with to set up a second "massage" with Epstein. Handwritten notes were found in Epstein's trash confirming this
. D. M A. (Jane Doe #18) and H. (Jane Doe #19) Jane Doe #18 was recruited by her brother's friend, Tony (referred to in indictment as "A.F."). Figueroa also was the former boyfriend (Jane Doe #1). Figueroa recruited several girls to Epstein's home includin R. Jane Doe #18 attended R2 al Palm Beac
simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa, 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857524_p7 →ough did an incredibly in-depth investigation for such a small police department). The defense also has complained repeatedly about the decision of the Palm Beach Police Chief to release information to the press and to complain loudly about State Attorney Barry Krisher's handling of the case. Giving the information
Page: EFTA02857524_p74 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857732_p4 →hough did an incredibly in-depth investigation for such a small police department). The defense also has complained repeatedly about the decision of the Palm Beach Police Chief to release information to the press and to complain loudly about State Attorney Barry Krisher's handling of the case. Giving the information
Page: EFTA02857732_p29 →simply subjects the defendant to a more severe penalty in light of Congress' concern about the sexual exploitation of minors. Cf. United States v. Figueroa , 165 F.3d 111, 115 (2d Cir. 1998) (noting that, if a criminal statute's language is unclear, its scienter requirement is presumed to be met once an
Page: EFTA02857763_p4 →hough did an incredibly in-depth investigation for such a small police department). The defense also has complained repeatedly about the decision of the Palm Beach Police Chief to release information to the press and to complain loudly about State Attorney Barry Krisher's handling of the case. Giving the information
Page: EFTA02857763_p45 →Entities connected to both The Palm Beach Post and Figueroa

Jeffrey Epstein
PERSON
Palm Beach
LOCATION
Bradley Edwards
PERSONJack Goldberger
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Alexander Acosta
PERSON
George W. Bush
PERSONJane Doe
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Palm Beach County
LOCATION
Bill Clinton
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Barry Krischer
PERSON
New York
LOCATION
U.S. Virgin Islands
LOCATIONLeon Black
PERSON