Epstein Secrets

se he had not talked to her he had not had “contact.” The law does not take such an absurdly narrow view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining “no contact” order as the same as a “stay-away order” and noting that a “stay-away order” usually “

m when he pled guilty to a state sex offense. 13. If Epstein suddenly and genuinely found some reason that he needs to attend the deposition of Jane Doe2 and believes that Judge Pucillio’s order unduly or unfairly restricts his ability to do so, he is free to take up the matter with Judge Pucillio.

08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 _____________________________________/ PLAINTIFF, JANE DOE’S MOTION FOR A PROTECTIVE ORDER ENFORCING NO CONTACT ORDER AND INCORPROATED MEMORANDUM OF LAW Plaintiff, Jane Doe, hereby joins in Jane Doe Nos. 2-

w view of what amounts to “contact.” See, e.g., BRYAN A. GARNER, BLACK’S LAW DICTIONARY (8th ed. 2004) (defining

________________________________/ PLAINTIFF, JANE DOE’S MOTION FOR A PROTECTIVE ORDER ENFORCING NO CONTA

reason that he needs to attend the deposition of Jane Doe2 and believes that Judge Pucillio’s order unduly o

have taken steps to object” to the plea agreement, and that they believed criminal prosecution to be “extremely important”). 4 See ANTONIN SCALIA & BRYAN A. GARNER, READING Law: THE INTERPRETATION OF LEGAL TEXTS 56 (2012). °° 18 U.S.C. § 3771(a) (2012) (enumerating eight rights), id. § 3771(c)(1) (requiring gov

cult for victims to discover after the fact that potential criminal charges against a criminal who has abused them have been secretly bargained away. Jane Doe Number One and Jane Doe Number Two, for example, were outraged when they discovered prosecutors had entered into an agreement blocking any prosecutio

cult for victims to discover after the fact that potential criminal charges against a criminal who has abused them have been secretly bargained away. Jane Doe Number One and Jane Doe Number Two, for example, were outraged when they discovered prosecutors had entered into an agreement blocking any prosecutio

under the Act even before charges are filed. [*73] C. COURTS RECOGNIZE THAT CRIME VICTIMS HAVE CVRA RIGHTS BEFORE CHARGING 4 See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts 56 (2012). % 18 U.S.C. § 3771(a) (2012) (enumerating eight rights); id. § 3771(c)(1) (requiring gove