Epstein Secrets

st the other person’s interest in seeking the discovery.” Harrison v. Burlage, 2009 WL 2230794 * 4 (S.D. Fla. 2009) (citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304 (11th Cir. 2001)). 9. The persons sought to be deposed would not have information probative of Jane Doe No. 4’s claims or Defend

was cheating on him?” (Exh. 3, p. 132); Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 3 of 8 ----- 4 * “[Jane Doe No. 4] testified also in deposition that she had been—there had been a videotape made of her and another female in various positions that some of he

; Plaintiffs Jane Does 2-7’s Response to Defendant’s Motion to Compel and/or Identify Plaintiffs in the Style of this Case (D.E. 144); Plaintiffs Jane Does’ 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8’s Motion for Protective Order as to Jef

the asserted right of access against the other party's interest in keeping the information confidentiarRomero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11* Cir. 2001). In balancing the competing interests, the court appropriately considers "whether allowing access would impair

ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou

ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum

t the other person’s interest in seeking the discovery.” Harrison v. Burlage, 2009 WL 2230794 at 4 (S.D. Fla. 2009) (citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 7. Plaintiffs great concern is that through leading questions Defendant’s counsel will inform Jane Doe No. 4’s parents about the abortions. Epstei

which she has not waived simply by virtue of being a plaintiff in a lawsuit for sexual abuse against a convicted sex offender. WHEREFORE, Plaintiff Jane Doe 4, respectfully requests that this Court issue a protective order prohibiting leading questions at the depositions of Jane Doe No. 4’s parents on the

asserted right of access against the other party's interest in keeping the information confidential." Romero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11' Cir. 2001). In balancing the competing interests, the court appropriately considers "whether allowing access would impair

red on FLSD Docket 06/18/2013 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARFCA JANE DOE #1 and JANE DOE #2, petitioners, vs. UNITED STATES OF AMERICA, respondent. ORDER GRANTING PETITIONERS' MOTION TO PROFFER GOVERNMENT CORRESPONDENCE IN SUPPORT O

e of discovery" Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11t' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process because the litigants and the courts

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, ROY BLACK, et al., Intervenors. INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY

apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard

M Document 326 Entered on FLSD Docket 04/15/2015 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING INTERVENOR'S MOTION FOR A PROTECTIVE ORDER This cause is b

, 180 (1st Cir. 2003)(Both the constitutional and the common law rights of access have applied only to judicial documents"); Chicago tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1311 (11th Cir. 2001) ("when applying the common law right of access federal courts traditionally distinguish between those items w

07 with the execution of the NPA but instead deferred any disclosure until after Mr. Epstein's plea of guilty in state court. 3 EFTA00621911 3. Jane Doe 2 was hostile to the efforts of the USAO and FBI to cooperate against Mr. Epstein, see Villafana Declaration, Dkt. 14 at pg. 4, 6, see Dkt. 361, Exhib

apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard

M Document 326 Entered on FLSD Docket 04/15/2015 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:08-CV-80736-ICAM JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING INTERVENOR'S MOTION FOR A PROTECTIVE ORDER This cause is b

ture of discovery" Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process because the litigants and the court

by-the ttemeyls-Offieer Mr. Edwards first saw a reference to the NPA on or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's emergency petition. That-pleading-was-the-first-publie mention-ef-the-neit-preseeution-agreement-and-the-fifst-diselesere-to-MirE4wards-(ead-thus-te