Epstein Secrets

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

s of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys

dings, it was reasonable for both parties to assume that their communications would remain confidential. Although the undersigned has not found any Eleventh Circuit cases that address this issue, the other Circuits that have addressed the issue have done so inconsistently. The First Circuit has held that a comp

s of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 (954) 414-8033 Fax: (954) 924-1530 Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys

confer with an attorney for the government and to pursue charges against Jeffrey Epstein in other Districts, their claim is not ripe. F2 Pursuant to Eleventh Circuit law, Respondent respectfully requests that the Court stay discovery in the matter pending its resolution of that motion, especially where Petitione

d Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC 2028 Harrison Street, Suite 202 Holl ood Florida 33020 Fax: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake Cit , Utah 84112 Fax: EFTA00205486 E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 Th

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00208098 Case 9:08-cv-80736-KAM Document 58 Enter

North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys

The Court further ordered that all of the pleadings in the case be sealed. Id. 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 6 EFTA00208120 Case 9:08-cv-80736-KAM Document 60 Enter

North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: [email protected] Attorneys

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). 8 EFTA00212579 Case 9:08-cv-80736-KAM Document 58 Enter

Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 841 12 Fax: E-mail: Attorneys for Jane Doe # 1 and Jane Doe # 2 15 EFTA00212586

and Jane Doe No. 2. See Exhibit 2. The proposed motion 2 JelTrey Epstein also attempted to block discovery of materials in this case, leading to an Eleventh Circuit ruling that the victims' discovery efforts were proper. Dori Epstein, 749 F.3d 999 (11th Cir. 2014). 3 Remarkably, even though the Court directed t

Submitted, /s/ Bradley J. Edwardk Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LE RMA , P.L. And Paul G. Cassell Pro Hoc Vice S.J. Quinney College of Law at the 12 EFTA00188712 EFTA00188713 Case 9:08-cv-80736-KAM Document 279 Entered on FLSD Docket 12/30/2014 Page 13 of 13 Attorneys for Jane Doe

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner'. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 8 EFTA00184851 CAsse€0338cov8EBB5614AW Obnaarrea0M-1EnEnt

North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: [email protected] Paul G. Cassell S.J. Quinney College of Law at the University of Utah 332 S. 1400 E. Salt Lake City, Utah 84112 (801) 585-5202 Fax: (801) 585-6833 E-mail: casselp(alaw.utah.edu Attorneys