Epstein Secrets

., Suite 2 Fort Lauderdale, FL, USA 33301 (954)-524-2820 Fax: (954)-524-2822 Email:[email protected] John Pottinger [ATTORNEY TO BE NOTICED] J. Stanley Pottinger PLLC 49 Twin Lakes Road South Salem, NY, USA 10590 (917)-446-4641 Email:[email protected] Paul G Cassell [ATTORNEY TO BE NOTICED] S.J. Quinn

aneous: Respondent: Sharon Churcher; Jeffrey Epstein DOCKET CASE NUMBER: 1:15cv7433 OTHER DOCKET CASE NUMBER: 1:17mc00025 U.S. Court of Appeals, Second Circuit, 17-01625 FILING DATE: 9/21/2015 JURISDICTION: Diversity JUDGE: Robert W. Sweet NATURE OF SUIT: 320 Assault, Libel & Slander FILING TYPE: Civil

g. Edwards, Fistos, Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale. FL, USA 33301 Fax: Emai John Pottinger [ATTORNEY TO BE NOTICED] J. Stanley Pottinger PLLC 49 Twin Lakes Road 1111.1Y, USA 1 Email: Paul G Cassell [ATTORNEY TO BE NOTICED] For internal use only For internal use only CONFIDENTIA

Page 4 V. Maxwell 1:15cv7433 OTHER DOCKET CASE NUMBER: 1:17mc00025 U.S. Court of Appeals, Second Circuit, 17-01625 FILING DATE: 9/21/2015 JURISDICTION: Diversity JUDGE: Robert W. Sweet NATURE OF SUIT: 320 Assault, Libel & Slander FILING TYPE: Civil

ffe, Weissing. Edwards. Fistos, Lehrman, P.L. 425 N. Andrews Ave.. Suite 2 Fort Lauderdale. FL. USA 33301 John Pottinger [ATTORNEY TO BE NOTICED] J. Stanley Pottinger PLLC 49 Twin Lakes Road 111.61 Al Paul G Cassell [ATTORNEY TO BE NOTICED] For internal use only For internal use only CONFIDENTIAL - PURSUANT

Page 4 V. Maxwell 1:15cv7433 OTHER DOCKET CASE NUMBER: 1:17mc00025 U.S. Court of Appeals, Second Circuit, 17-01625 FILING DATE: 9/21/2015 JURISDICTION: Diversity JUDGE: Robert W. Sweet NATURE OF SUIT: 320 Assault, Libel & Slander FILING TYPE: Civil

le FL 33301 Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale. FL 33301 J. Stanley Pottinger 49 Twin Lakes Rd. South Salem NY 105 0 Is/ Nicole Simmons Nicole Simmons 9 EFTA00595621 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NE

es statement contained in the report) will never be admissible unless there is a separate and independent hearsay exemptions for such statement. As the Second Circuit has clearly held: "It is well established that entries in a police report which result from the officer's own observations and knowledge may be adm

LLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards Stan J. Pottinger EDWARDS POTTINGER LLC 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad @pathtojustice.com [email protected] Christine N. Walz

otions for dismissal or summary judgment." Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019) (citing United States v. Amodeo, 71 F.3d 1044, 1049-50 (2d Cir. 1995) ("Amodeo II")); (b) any minimum presumption of public access is subject to many countervailing interests supporting continued sealing; and (c

cited with approval in SEC v. TheStreet.com, 273 F.3d 222, 232 (2d Cir. 2001), which was cited with approval in Brown, 929 F.3d at 51 n.40. Notably the Second Circuit in Brown held that redactions of sensitive, private information disclosed by witnesses in depositions because of "a strong expectation of continued

d McCawlpa Pottinger, Brad Edwards, or Peter Skinner; and (2) did not interview anyone other than AUSA such as the other attendees of the meeting (Pottinger, Edwards, and Skinner), or any of the other AUSAs whom AUSA talked to about her contacts with attorneys. Most conspicuous, of course, is the gove

that 'implies the duty of establishing and maintaining civilized standards of procedure and evidence.'" United States v. Ming He, 94 F.3d 782, 789 (2d Cir. 1996) (quoting McNabb, 318 U.S. at 340). As the Supreme Court held in United States v. Payner, "Federal courts may use their supervisory power in s

Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied on the Protective Order. 20 EFTA00028953 --- PAGE BREAK --- reports were replete with misrepre

wle , Stan Pottinger, Brad Edwards, or Peter Skinner; and (2) did not interview anyone other than AUSA such as the other attendees of the meeting (Pottinger, Edwards, and Skinner), or any of the other AUSAs whom AUSA talked to about her contacts with attorneys. Most conspicuous, of course, is the gove

that 'implies the duty of establishing and maintaining civilized standards of procedure and evidence.'" United States v. Ming He, 94 F.3d 782, 789 (2d Cir. 1996) (quoting McNabb, 318 U.S. at 340). As the Supreme Court held in United States v. Payner, "Federal courts may use their supervisory power in s

Cir. 2019) (citing Fed. R. Civ. P. 5.2). So, too, has Judge Preska redacted substantial material from the documents she has released on remand from the Second Circuit, again reflecting that Maxwell reasonably relied on the Protective Order. 20 EFTA00029124 --- PAGE BREAK --- reports were replete with misrepre