Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of through his counsel comply within days i.e by June As such this motion must be respectfully addressed before June As part of that order at DE this court ruled that Plaintiff shall not disclose Defendants tax returns to any third parties without Defendants consent and/or further court order and Plaintiff may disclose this information to an expert witness retained to testify at trial but only on condition that the expert will agree to retain the confidentiality of the information and not disclose it to any third parties without the agreement of defendant or further order of the Court The order went on to state that it is without prejudice to any future motion by defendant to exclude any of the information produced pursuant to this order at trial As to the information given to Epsteins lawyers by the federal government as outlined in DE the court did not address in DE any order of confidentiality As a result of the foregoing and consistent with DE related to tax returns and passport Epstein hereby requests that this court enter an order a limiting Mr Edwards and Jane Does use of the information given to Epsteins lawyers by the federal government only to this litigation ordering that the information not be disclosed to any third parties without the consent of the Defendant or further order of this court which includes news and television media requiring as it did relative to the tax returns and the passport that any expert that receives the information given to Epsteins lawyers by the federal government must be one retained to testify at trial and shall only receive said information on condition that the expert will agree to retain the confidentiality of the information Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of and not disclose it to any third parties without the agreement of defendant or further order of the Court that the information given to Epsteins lawyers by the federal government be returned to Epsteins lawyers at the conclusion of this trial that failure to follow the courts directives set forth in said order shall result in contempt of court and for such other and further relief as this court deems just and proper WHEREFORE Defendant JEFFREY EPSTEIN requests the Court enter a protective order and confidentiality order incorporating the terms set forth in paragraph 5a-f and grant any additional relief the Court deems just and proper Local Rule Statement Pursuant to the above rule the undersigned counsel and Plaintiffs counsel have conferred and were unable to reach an agreement Isl Robert Critton Jr Robert Critton Attorney for Defendant Epstein Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day ose of reoonl oo the foHowiog loo list io fue spocy transmission of Notices of Electronic Filing generated by CM/ECF on this Jj_day of Brad Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Ave Suite Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Fort Lauderdale FL Phone Fax Brad pathtojustice.com Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp aw.utah.edu Co-counsel for Plaintiff Fax jagesg bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully submitted By Isl Robert Critton Jr ROBERT CRITTON JR ESQ Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Boulevard Suite West Palm Beach FL Phone Fax Co-Counsel for
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