Epstein Secrets

nsel would like to refer to the non-prosecution agreement in a parallel civil suit that is pending before this court, See Jane Doe Jeffrey Epstein, United States District Court, Southern District of Florida, Case No.: 08-C111- 80893-AtiRRii-JOHNSON. To facilitate all these discussions, the non-prosecution agreement 5 EFTA0

cuments will be disclosed and there will be no adequate remedy. Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, E.W., B.B. and The Post are referred to as E.W., B.B. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A

ith notice to the United States, the other party to the Agreement. (A-6). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen

1 F. Supp. 1299 (M.D. Fla. 1977) 23, 24 Lockhead Martin Corp. I. Boeing Co., 393 F. Supp. 2d 1276 (M.D. Fla. 2005) 23 Oregonian Publishing Co.'. United States District Court, 920 F.2d 1462 (9th Cir. 1990) 9 U.S. I Rosen, 471 F. Supp. 2d 651 (E.D. Va. 2007) 23 United States'. Kooistra, 796 F.3d 1390 (11th Cir. 1986)

for respondent, State of Florida) B.B. (non-party intervener) William J. Berger of Rothstein Rosenfeldt Adler (counsel for non-party intervener, E.W.) Honorable Jeffrey J. Colbath (circuit court judge) Barbara J. Compiani of Kreusler-Walsh, Compiani & Vargas, P.A. (appellate counsel for petiti

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

, Jane Doe v. Epstein, No. 9:08-cv-80893-Marra/Johnson (S.D. Fla.)) and/or a related federal Crime Victims' Rights Act lawsuit currently pending in the U.S. District Court for the Southern District of Florida (e.g., Jane Does 1 Sr 2. v. United States, No. 9:08-cv-80736-KAM (S.D. Fla.)). You also appear to have other c

tions in connection with 2 EFTA00793292 these materials so that I can be certain that you have fully protected the rights of third parties L.M., E.W., and Jane Doe. Respectfully submitted, Paul G. Cassell, Esq. for L.M., E.W., and Jane Doe 3 EFTA00793293