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rted "upon information and belie?' that they understood that Epstein was involved in on-going plea negotiations with the U.S. Attorney's Office for the Southern District of Florida. Victims' Petition (doe. #1) at 1. On July 9, 2008, the Government responded with a sealed response (quickly unsealed by the Court), that
10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl
rted "upon information and belie?' that they understood that Epstein was involved in on-going plea negotiations with the U.S. Attorney's Office for the Southern District of Florida. Victims' Petition (doe. #1) at 1. On July 9, 2008, the Government responded with a sealed response (quickly unsealed by the Court), that
cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag
of any certain set of facts, other than whether a charging document was ever filed against Jeffrey Epstein in the United States District Court for the Southern District of Florida. And while this Office remains willing to cooperate, cooperation does not mean agreeing to facts that arc not relevant to the resolution
r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.
Entities connected to both the Southern District and Steinger

Jeffrey Epstein
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSONLeon Black
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSON
Paul Cassell
PERSONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Barry Diller
PERSON
Supreme Court
ORGANIZATION
West Palm Beach
LOCATIONCourtney Wild
PERSONFISTOS & LEHRMAN
ORGANIZATION
the University of Utah
ORGANIZATION