Case 9:08-cv-80893-KAM Document 217 Entered on FLSD Docket 09/13/2010 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-IVIARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, et al. Defendant. REAL PARTY IN INTEREST BRADLEY J. EDWARDS, ESQ.'S RESPONSE TO JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS Even though this particular case has been dismissed, defendant Jeffrey Epstein has filed a motion in it seeking to block the use of certain incriminating correspondence in a separate state proceeding that he himself initiated against Jane Doe's attorney, Bradley J. Edwards. Epstein's motion should be denied because there is no basis for a federal court to enter a new order blocking disclosure of correspondence in that state case. If Epstein believes he has a valid basis for preventing disclosure, he should raise the point there in the lawsuit that he chose to file. And, in any event, he has no valid basis for prevent disclosure, because this Court has already rejected all of his arguments. Finally, to the extent Epstein is attempting to bar use of the correspondence in a Crime Victims Rights Act case against the U.S. Attorney's Office, he is not a party to that proceeding. Therefore, his motion should be denied for this reason as well. EFTA00724381