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efta-efta00209256DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

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Unknown
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DOJ Data Set 9
Reference
EFTA 00209256
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5
Persons
7
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), through counsel, hereby move to seal their DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER for the following reasons: 1. This Honorable Court's Order [DE 249 at I] states that "...petitioners should not comply with the Order Granting Petitioners' Motion to Proffer Government Correspondence in Support of CVRA Claims & Granting Motion to Unseal Correspondence and Related Unredacted Pleadings of Petitioners (DE 188) until further order of this Court." 2. Petitioners seek leave to file this DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER under seal, in an abundance of caution, because it

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), through counsel, hereby move to seal their DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER for the following reasons: 1. This Honorable Court's Order [DE 249 at I] states that "...petitioners should not comply with the Order Granting Petitioners' Motion to Proffer Government Correspondence in Support of CVRA Claims & Granting Motion to Unseal Correspondence and Related Unredacted Pleadings of Petitioners (DE 188) until further order of this Court." 2. Petitioners seek leave to file this DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER under seal, in an abundance of caution, because it discusses material that Epstein has Moved to prevent the disclosure of, and the Court has ordered the victims not to file other similar material in its previous Order [DE 249]. EFTA00209256 3. While the victims, for all of the reasons stated previously by this Court and those recounted within their Response, do not believe that their Response or any of the materials contained therein should be sealed, we are proceeding with extreme caution so as to allow the Court to definitively decide that issue before any materials subject to Epstein's Motion are made part of the public file. WHEREFORE, Petitioners respectfully request that DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER be sealed until further order of the Court. Alternatively, if the Court denies the instant motion to seal, then Petitioners respectfully request that their Response in Opposition to Epstein's Motion for Protective Order be filed in the public file and docketed as of today's date, as timely filed. DATED: May 16, 2014. Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice los EFTA00209257 Attorneys for Jane Doe #1 and Jane Doe #2 EFTA00209258 CERTIFICATE OF SERVICE I certify that the foregoing document was served on May 16, 2014, on the following using the Court's CWECF system: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Black, Srebnick, Kornspan & Stumpf, P.A. Jay P. Le0cowitz Kirkland & Ellis, LLP om Martin G. Weinberg, P.C. nos Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards EFTA00209259 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. ORDER GRANTING MOTION TO SEAL It is hereby ordered that DOE I AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER be sealed until further order of this Court. DONE AND ORDERED in Chambers at Palm Beach County, Florida, this day of May. 2014. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE EFTA00209260

Related Documents (6)

DOJ Data Set 9OtherUnknown

U.S. Department of Justice

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3

Case 9:08-cv-80736-KAM Document 224 Entered on FLSD Docket 08/16/2013 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S NOTICE OF FILING OF OBJECTIONS TO PRIVLEGE LOG COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to give notice of their filing of objections to the Government's two privilege logs (DE 212 and DE 216). The objections are attached hereto. The victims are filing these objections concurrently with a motion to compel production of the materials at issue. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley 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 E-mail: brad ®pathtojustice

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-ev-80736-Civ-ICAM JANE DOE 1 and JANE DOE 2 I UNITED STATES JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned counsel, to file this response in opposition to Epstein's Motion for a Protective Confidentiality Order (DE 247). Epstein's motion is a thinly-disguised attempt to relitigate issues already covered by the court's earlier ruling eleven months ago (DE 188), which allowed the victims to file correspondence relating to Epstein's non-prosecution agreement in the public court file. Rather than reverse its previous ruling, this Court should reaffirm it — and allow the important issues presented by this case to be litigated in the light of day. BACKGROUND Because of Epstein's penchant for relitigating issues that have already been decided, it

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DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

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DOJ Data Set 9OtherUnknown

Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23

Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use,

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DOJ Data Set 9OtherUnknown

Case No. 08-80736-CV-MARRA

Case No. 08-80736-CV-MARRA P-0 I 1789 EFTA00192835 Memorandum Subjeci Operation Leap Year: Notification of Breach USAO No. 2006R0 181 June 9, 2009 To Jeffrey H. Sloman Acting United States Attorney Robert K. Senior First Assistant U.S. Attorney Rolando Garcia Deputy Chief, Criminal Division, West Palm Beach Karen Atkinson, Chief Chief, Criminal Section I, Northern Division, WPB From A. Marie Villafan AUSA, Ft Laude INTRODUCTION. This memorandum seeks approval to serve the attached letter providing notice of a breach of the Non-Prosecution Agreement on attorneys for Jeffrey Epstein. On Friday, June 12, 2009, Judge Marra will be presiding ova a hearing on Jeffrey Epstein's motions to stay all of the civil lawsuits filed against him by victims identified through our investigation. In his Order setting the matter for a hearing, Judge Marra stated: This hearing shall be limited to the issue of whether Defendant Epstein's defense of the civil actions filed against h

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