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ern District of Florida. However, the NP A does not provide Epstein with any protection from criminal investigation or prosecution in other than in the Southern District of Florida. As the court has acknowledged in its orders ( e.g., 9 Case 9:08-cv-80119-KAM Document 477 Entered on FLSD Docket 02/26/2010 Page 10 of 24
United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, I 50-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited
tion. Moreover, fue NP A does not provide Epstein with any protection from criminal investigation or prosecution in any federal district other than the Southern District of Florida. The Second Amended Complaints and Plaintiff Response at DE 485, p.18 include averments that Epstein both resided in and engaged in illegal sexual
United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited
all pertain to the negotiation and eventual entering into of a Non-Prosecution Agreement (NPA) with the United States Attorney's Office (USAO) for the Southern District of Florida. See part I above herein. Again, the constitutional issues raised in Defendant's response permeate these discovery requests. The full text of Feder
ited States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free from uninvited o
Entities connected to both Southern District of Florida and Shaktman

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
Bradley Edwards
PERSON
Ghislaine Maxwell
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Harry Reid
PERSON
Jay Lefkowitz
PERSON
Adam D. Horowitz
PERSON
Alan Dershowitz
PERSON
Supreme Court
ORGANIZATIONSecond Circuit
ORGANIZATIONRobert C. Josefsberg
PERSON
Salt Lake City
LOCATIONStuart S. Mermelstein
PERSONMichael J. Pike
PERSONScott Rothstein
PERSON
Sarah Kellen
PERSON