Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of through his couusel comply within days i.e by Juue As such this motion must be timely addressed 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 Plaintiffs counsel here and in other cases has always been quick to respond to media inquiries The court has directed that the tax returns themselves remain confidential Defendant expects that the information contained therein will be afforded that same protection However if Plaintiffs couusel provides information such as the identification and sources of Defendants income to others i.e non-lawyers investigators etc they will use that information in an improper manner and in violation of the courts order As set forth in DE Mr Edwards admittedly has provided the journal and/or book secured from Alfredo Rodriguez to his investigators who are now following-up alleged significant discovery leads found in the book Therefore Epstein in good faith moves this court for an order allowing him to redact certain information or designate the documents produced Attorneys and Experts Eyes Only While the tax returns in this case are to be maintained as confidential certain information should be redacted in those tax returns including but not limited to the names of the Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of companies trusts properties and other investment vehicles EPSTEIN has invested in over the years This information is personal confidential and trade secret information The commercially sensitive and trade secret information contained in the tax returns could result in irreparable harm to Epstein if disseminated and thus should be protected Lynch Silcox WL S.D Fla Saye Old Hill Partners Inc F.Supp D.Ct Conn question of fact existed as to whether investment companys business formula which included investment trading strategy investor lists portfolios financing methods was trade secret see also U.S Baez-Alcaino Supp M.D Fla affirming lower courts decision to file redacted plea agreements to serve compelling government interests In re Duque B.R S.D Fla finding that courts procedure requiring attorneys to provide privileged documents to court for in-camera inspection while providing redacted versions to the bankruptcy trustee was proper No figures or income information in the tax returns will be redacted Moreover the right to privacy encompasses at least two different kinds of interests the individual interests of disclosing personal matters and the interest in independence in making certain kinds of important decisions Favalora Sidaway So.2d Fla th DCA Likewise Article I Right of Privacy provides that every natural person has the right to be let alone and free from governmental intrusion into the persons private life Colorado Bertine U.S State Jardines So.3d I Fla 3d DCA the Fourth Amendment clearly protects the right of people to be secure in their persons houses papers and effects from intrusion While the scope of discovery is broad it is not without limits Washington Brown Williamson Tobacco F.2d 11th Cir Courts have long held Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of that while the standard of relevancy in discovery is a liberal one it is not so liberal as to allow a party to roam in the shadow zones of relevancy and to explore matters which does not presently appear germane on the theory that it might conceivably become so Food Lion Inc United Food Commercial Workers Intern Union F.3d C.A D.C string cite omitted See also Capco Properties LLC Monterry Gardens of Pinecrest Condo So 2d Fla 3d DCA holding that discovery in civil cases must be relevant to the subject matter of the case and must be admissible or reasonably calculated to lead to admissible evidence Morton Plant Hospital Assn Inc Shahbas So 2d Fla 2d DCA holding that discovery should be denied when it has been established that the information requested is neither relevant to any pending claim or defense nor will it lead to the discovery of admissible evidence citing Tanchel Shoemaker So 2d Fla 5th DCA At this juncture and in an effort to comply with the above order Epstein is producing the redacted versions of the tax returns until further order from the court WHEREFORE Defendant JEFFREY EPSTEIN requests the Court enter an order and/or protective order allowing Epstein to redact the above information 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 Robert Critton Jr Robert Critton Attorney for Defendant Epstein Certificate of Service Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of 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 on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this JQ_day of Brad Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Ave Suite Fort Lauderdale FL Phone Fax Brad a pathtoiustice.com Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Co-Counsel for Defendant Jeffrey Epstein Respectfully submitted By Isl Robert Critton Jr ROBERT CRITTON JR ES Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike albclclaw.com BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Boulevard Suite West Palm Beach FL Phone Fax Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of Co-Counsel for
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