Epstein Secrets

e allegations are wholly impertinent to the issues in the Joinder Motion or the Federal Action more generally. Indeed, United States District Judge Kenneth Marra has already concluded — in an unchallenged order that is binding on Edward and Cassell in this action — that the allegations were "unnecessary," "i

r at the very least were "grossly negligent" in defaming Dershowitz, which would support his claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about Dershowitz are "impertinent" to the issues in the federal proceeding and ordered them to be stricken

claim for punitive damages: • On April 7, 2015, Judge Marra expressly held that "lurid" allegations about D

end, it would be an abuse of discretion for the Court to deny Dershowitz's request. 15 EFTA00613405 Respectfully submitted, s/ Thomas E. Scott Steven R. Safra, FBN 057028 COLE, SCOTT & KISSANE, P.A. Richard A. Simpson (pro hac vice) Ma E. Bo 'a ro hac vice) Ashle E. Filer ro hac vice) Nicole Audet Ric

ncluding Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See Exhibit A. Judge Mar

assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations w

sition of Jane Doe No. 3. 21 EFTA00582669 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations w

ncluding Prince Andrew. That the allegations were improper and irresponsible is not merely an assertion by Dershowitz; United States District Judge Marra has expressly held that the "lurid" allegations were "unnecessary," "immaterial," and "impertinent" to the federal lawsuit. See Exhibit A. Judge Mar

sition of Jane Doe No. 3. 19 EFTA00584080 Dated: May 2015 Respectfully Submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Steven R. Safra Florida Bar No. 057028 COLE, SCOTT & KISSANE, Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156 Phone: (305) 35

United States of America Case No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").

, West Palm Beach, Florida 33409. Respectfully submitted, 5/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 Thomas.scott @csklegal.com Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Cole, Scott & Kissane Building, 14th Floor 9150 South Dadeland Boul

15595 --- PAGE BREAK --- Dated: February 3, 2016 Respectfully submitted, s/Thomas E. Scott Thomas E. Scott, FBN 149100 [email protected] Steven R. Safra, FBN 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Florida 33156

ral part of the civil proceeding, particularly when the condition is asserted as an issue by the party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE RECORDS BE SEALED IN THIS CASE. Dershowitz also appears to contend that Judge Marra’s order striking s

he party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE REC

lief from that Confidentiality Order. Respectfully submitted, s/ Thomas E. Scott Thomas E. Scott Florida Bar No. 149100 [email protected] Steven R. Safra Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th Floor 9150 South Dadeland Boulevard Miami, Flo

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, VS. U

HERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED ST

) 646-4466 Fax: (617) 646-4470 Respectfully submitted, /s/ Thomas E. Scott Thomas E. Scott, Esq. Florida Bar No. 149100 [email protected] Steven R. Safra, Esq. Florida Bar No. 057028 [email protected] COLE, SCOTT & KISSANE, P.A. Dadeland Centre I], 14th Floor 9150 South Dadeland Boulevard Miam