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t who asserts the Fifth Amendment privilege "may have to accept certain bad consequences that flow from that action? Mid-America's Process Serv. v. Ellison, 767 F.2d 684, 686 (10th Cir. 1985). 10 EFTA00722675 Case 9:08-cv-80893-KAM Document 31 Entered on FLSD Docket 04/09/2009 Page 11 of 14 Here
v. JEFFREY EPSTEIN, Defendant. MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR, IN THE ALTERNATIVE, TO LIFT PROTECTIVE ORDER BARRING JANE DOE'S ATTORNEY'S FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution
ent in parallel litigation under the Crime Victim's Rights Act. Doe v. United States, No. 9:08-CV-80736-KAM. The agreement, however, was provided to Jane Doe's counsel subject to a protective order. That protective order precludes Jane Doe's 3 EFTA00722661 Case 9:08-cv-80893-KAM Document 32 Entered on
t who asserts the Fifth Amendment privilege "may have to accept certain bad consequences that flow from that action? Mid-America's Process Serv. v. Ellison, 767 F.2d 684, 686 (10th Cir. 1985). 10 EFTA00201245
ons asked and the documents requested . . . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Atnendment principles
8, Katersky, Rubin), Rolling Stone (04/18, Bort, Legaspi), The Intercept (04/18, Maass), Business Insider (04/18, Shamsian), and Vanity Fair (04/18, Ellison) also reported on the story. Russian Court Upholds WSJ Reporter Evan Gershkovich's Detention The Wall Street Journal (04/18, Simmons) reported that
a second day. The New York bank, the nation's largest, has been sued by the government of the U.S. Virgin Islands and two women, both identified as Jane Doe, who say they were abused by Epstein. The lawsuits contend JPMorgan should have seen evidence of Epstein's sex trafficking and avoided profiting fr
Entities connected to both Ellison and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSON
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Virginia Giuffre
PERSON
Sarah Kellen
PERSONMartin Weinberg
PERSON
Donald Trump
PERSON