Epstein Secrets

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

Clerk theolyil e cad dwa. IS CI INSTRUCTIONS ON THE REVERS( Of THE FOAMS NOTICE: Altorneys MUST Indicate All Re-filed I. (a) PLAINTIFFS -177 re: Jane Poe DEFENDANTS 5-thfeso/ - fttectagi OW 0 D.C. JULY 7, 2008 STEVEN M.LARIMORE CLERK U.S. 01ST. CT. 6.0. Of ILA. - MIAMI (b) Comb &Residence &Pi

ce of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe'. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRA-JOHNSON. Although Epstein's counsel has n

l injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal. Allstate Ins. Co.'. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co. I. EFTA00184085 McGuire, 670 So.2d 153 (Fla. 4th DCA 1996); see, Menke' Broward School Bd, 916 So.2d 8

s Doe vs. Epstein 2 cases. 3 May I have counsel state their appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good mo

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

ce of this motion to Jeffrey Epstein, through counsel. Jeffrey Epstein's counsel has entered an appearance in several related civil suits, including Jane Doe v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08- CIY-80893-MARRAJOHNSON. Although Epstein's counsel has

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

cument in Court File" (A-9). An addendum to the non-prosecution agreement was filed under seal on August 25, 2008. On July 7, 2008, Jane Doe I and Jane Doe 2 filed an independent action in federal court to compel production of the non-prosecution agreement (A-1). Mr. Epstein was not a party to the procee

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 M. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement an

cuments are subject to confidentiality provisions, which the federal court recognized and enforced when it permitted disclosure to the attorneys for Jane Doe 1 and Jane Doe 2 and to any other victims and their counsel, provided they not disclose the terms to anyone else. Disclosure violates a condition of t

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL

xpenses, deposition related costs, expert costs, etc.) that were incurred by_ysiu in the representation of you and/or your law firm in representing Jane Doe, M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL

expenses, deposition related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and

tted to discover relevant evidence that would be inadmissible at trial, if it may lead to the discovery of relevant evidence." Allstate Ins. Co. v. Langston, 655 So. 2d 91, 93 (Fla. 1995). As provided in detail below, Edwards's objections to 3 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL

expenses, deposition related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and

l injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal. Allstate Ins. Co.'. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co.'. EFTA00233732 McGuire, 670 So.2d 153 (Fla. 4th DCA 1996); see, Menke'. Broward School Bd, 916 So.2d 8

tered on FLSD Docket 07/15/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOE, Petitioner. FILED by JUL 0 9 2008 STEVEN N. LAMMORE CLERK U.S MST. CS s.o. or nA.-wra. GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY PETITION F

to protect a non-party from discovery that would result in “annoyance, embarrassment, oppression or undue burden or expense...” Al/state Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court overturning denial of protective order and holding that “[d]iscovery of certain kinds of inform

lations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-known criminal defense attorney. Epstein required Jane Doe #3 to have sexual relations with Dershowitz on numerous occasions while she was a minor, not only in Florida but also on private planes, in New York, N