Epstein Secrets

v. JEFFREY EPSTEIN, Defendant. MOTION TO STRIKE REFERENCES TO NON-PROSECUTION AGREEMENT OR, IN THE ALTERNATIVE, TO LIFT PROTECTIVE ORDER BARRING JANE DOE'S ATTORNEY'S FROM REVEALING PROVISIONS IN THE AGREEMENT Plaintiff, Jane Doe, hereby moves this Court to strike all references to a "non- prosecution

ent in parallel litigation under the Crime Victim's Rights Act. Doe v. United States, No. 9:08-CV-80736-KAM. The agreement, however, was provided to Jane Doe's counsel subject to a protective order. That protective order precludes Jane Doe's 3 EFTA00722661 Case 9:08-cv-80893-KAM Document 32 Entered on

n defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights? Epstein Motion to Stay at 2. Epstein goes on to state: 'As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement) by: 1. Investiga

ons asked and the documents requested . . . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Atnendment principles

defending the civil claims in that he has no Idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights." Epstein Motion to Stay at 2. Epstein goes on to state: "As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement] by: 1. Investiga

n filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08- CIV 80893 MARRA/JOHNSON. Plaintiffs concur in the arguments made by Jane Doe's counsel in that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same reasoning and arguments apply in the instant cas

er plaintiffs. Finally, Epstein concedes that the Court should consider 'the interest of the public" in being the litigation to a rapid conclusion. Epstein Motion to Stay at 6. As the Court is aware, this case involves a non-prosecution agreement with a politically- connected billionaire that has drawn considerable pu

ions asked and the documents requested .. . ." Id. Here Epstein has made sweeping generalizations about the applicability of the Fifth Amendment to Jane Doe's specific discovery requests. But in his motion, he has merely cobbled together a few grandiose quotations about general Fifth Amendment principles

defending the civil claims in that he has no idea what the USAO will define as a breach in the event he does not assert his 5th Amendment rights." Epstein Motion to Stay at 2. Epstein goes on to state: "As an example, the USAO has already claimed that Epstein violated the [non-prosecution agreement] by: 1. Investiga