Epstein Secrets

ying 13:25 far 11:12 10:2,5,11 entered 13:17 four 10:15,20,24 7:3 6:12,16 7:3 Federal 13 20 11:3,14,17 desire entitled 6:10 7:9 14 Frida EFTA00233785 Proceedings 13:10 14:17 14:18 gives 8:9, 10 go 5:5 7:18,18 8:22 10:11 11:12,23,25 12:4 13:7 13:25 15:11 goes 5:24 going

orum in which to disclose these facts. •4 Although there is no case directly on this point, the present question comes fully within the holding of Barron, which thoroughly considered the com- petition between the people's interest in public courts and the personal interest in private facts. In effect

rong presumption in favor of public ac- cess to such matters." Sentinel Communications Co. I Watson, 615 So.2d 768, 770 (Fla. 5th DCA 1993) (citing Barron I Florida Freedom Newspapers, Inc., 531 So.2d 113 (Fla.1988)). This presumption rests on the most fundamental values of American government. O200

lic identification. However, Barron teaches that this is the wrong question because it overlooks the higher purpose of openness in the courts. In Barron, a case involving privacy concerns inher- ent in a divorce case, the court strongly reaffirmed the presumption that Florida civil courts are open.

least restrictive means necessary to accomplish its purpose. The Florida Supreme Court held in Barron v. Florida Freedom Newspapers, 531 So. 2d 113 (Fla. 1988), that a sealing order can be entered only where “no reasonable alternative is available to accomplish the desired result, and, if none exists,

W. Florida law requires that any sealing order be the least restrictive means necessary to accomplish its purpose. The Florida Supreme Court held in Barron v. Florida Freedom Newspapers, 531 So. 2d 113 (Fla. 1988), that a sealing order can be entered only where “no reasonable alternative is available to

- PAGE BREAK --- EXHIBIT D HOUSE_OVERSIGHT_015618 --- PAGE BREAK --- IN THE CIRCUIT COURT OF THE 171% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION BRADLEY J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs, Vv. ALAN DERSHOWITZ, Defendant. [PROPOSED] CONFIDENTI

12 561-659-8300 Fax: 561-835-8691 janeso@bellsouthriei Counsel for Defendant Jeffrey Epstein Respectfully submi By: ROBERT CRITTON,112., ESQ. Flovida No. 224162 MICHAEL J. ME, ESQ. Florida Bar #617296 =Was :14mm BURMAN, CRITTON, LIJItER & COLEMAN 303 Banyan Blvd., Suite 400 West Palm Beach,

REBY CERTIFY that a truc copy of the foregoing wes hand-delivered to die Clerk of the Court as required Dy the Local Ru/es of the South= District of Floride and eleceonically =Wied to all enquise; of record idendfied on the following Service List on this JJig day of Scptembes, 2009. Certifient of Servi

the news media, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and records. See Barron v. Florida Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'a