Epstein Secrets

Sixth and Fourteenth Amendment privileges afforded him under the United States Constitution. Mr. Kuvin also knew an order was issued in the related Federal Court proceedings sustaining Epstein's 5th Amendment privilege as to questions that, if answered, EFTA00728127 v. stein ase No. 2008CA037319XXXXMBAB

ion his case in the public light. This is clearly effecting Epstein's right to obtain a fair and just trial. State ex rel. Miami Herald Pub. Co. v. McIntosh, 340 So.2d 904, 910-11(1976)(Muzzling lawyers who may wish to make public statements to gain public sentiment for their clients has long been recog

h apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that,

Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion Tower 1601 Forum Place, Suite 1110 West Palm Beach, Florida 33401 Fax. 561 682-3206 Counsel for Defenda

e? MR. GoLDBERGER: Yee. THE COURT' As opposed to any criminal prosecution going on? MR. GOLDBERGER: It is civil proceedings that are going on in Federal Court. But in the interest of comedy, Your Honor, the Court has ruled on the confidentiality agreement and has put a well reasoned procedure into place.

e press have a fundamental right of access to all judicial proceedings," however, this right is not absolute. State ex rel. Miami Herald Pub. Co. McIntosh, 340 So.2d at 908-9. In Bar- ron, the court took the occasion to establish the standards upon which the presumption of openness may be overcome whe