Epstein Secrets

, 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

n M. Dershowitz,' which support and/or confirm the allegations set forth in Paragraphs 24-31 of your Declaration dated January 19, 2015, filed with the United States District Court for the Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America Case No. 08-80736-CIV-MARRA/JOHNSON, [ECF No. 291

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

d among Epstein, the Government and Epstein's alleged victims during the plea negotiations. 9 EFTA00613417 22. On April 7, 2015, Judge Marra of the United States District Court for the Southern District of Florida confirmed, as a matter of law, the impertinence of the Joinder Motion's allegations about Dershowitz abusing

tion to place Plaintiff Alan Dershowitz's Affidavit exhibit filed as an attachment to his Motion in Limine under seal. Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar No. 14 100 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th

ecord. As Plaintiffs' recently argued in persuading this Court to deny Dershowitz's motion to file under seal allegations that had been stricken by the United States District Court for the Southern District of Florida: To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing of "confidential" materials

tion to place Plaintiff Alan Dershowitz's Affidavit exhibit filed as an attachment to his Motion in Limine under seal. Respectfully submitted, /s/ Steven R. Safra Thomas E. Scott, Esq. Florida Bar No. 14 100 Steven R. Safra, Esq. Florida Bar No. 057028 COLE, SCOTT & KISSANE, P.A. Dadeland Centre II, 14th

ecord. As Plaintiffs' recently argued in persuading this Court to deny Dershowitz's motion to file under seal allegations that had been stricken by the United States District Court for the Southern District of Florida: To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing of "confidential" materials

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

ACKGROUND This defamation action arises out of an underlying lawsuit that Edwards and Cassell filed against the United States (the "Government") in the United States District Court for the Southern District of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain

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

ACKGROUND This defamation action arises out of an underlying lawsuit that Edwards and Cassell filed against the United States (the "Government") in the United States District Court for the Southern District of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain