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No. 08-80736-CIV-MARRAMATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 Paul G. Cassell S.J. Quinney College
vernment." See supra at 1-3. The Respondent also objects to Requests No. 26(a)-26(e) as calling for responses that are protected from disclosure by Federal Rule of Criminal Procedure 6(e), by the law enforcement investigative privilege, and by the work product doctrine. Notwithstanding the foregoing objection, the Resp
the victims have offered. DATED: March 21, 2011 Respectfully Submitted, l Bradley J. Edwards adley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075
ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei
ex offenses he committed against many children," said Bradley Edwards, the women's trial counsel and a partner at Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman in Fort Lauderdale. Edwards said the documents at this point will be disclosed only to the plaintiffs and will not become part of the public record
he United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the cowl should find that the m
Entities connected to both FISTOS & LEHRMAN and Federal Rule of Criminal

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONMaria Farmer
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSON
Weissing
PERSONthe Southern District
LOCATIONJack Goldberger
PERSON
S.J. Quinney College of Law
ORGANIZATION
United States
LOCATION
Alan Dershowitz
PERSON
the University of Utah
ORGANIZATIONLeon Black
PERSON
Salt Lake City
LOCATION
George W. Bush
PERSON
Ghislaine Maxwell
PERSONScott Rothstein
PERSONJack Scarola
PERSON