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

ion that civil and criminal cases proceed together." United States ex reL Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

a stay only after that defendant has been indicted." United States ex rel. Gonzalez v. Fresenius Medical Cam North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil proc

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

on that civil and criminal cases proceed together." United States ex rel. Gonzalez v. Fresenlus Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

stay only after that defendant has been indicted." United States ex rel. Gonzalez v. Fresenius Medical Care North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil proc

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

on that civil and criminal cases proceed together." United States ex rel. Gonzalez I. Fresenius Medical Care North America, 571 F.Supp.2d 758, 761 (W.D. Tex. 2008) (internal quotation omitted). Epstein has shown no good reason for deviating from normal practice here. One last reason weighing against a

stay only after that defendant has been indicted." United States ex rel. Gonzalez I. Fresenius Medical Care North America, 571 F.Supp.2d 758, 763 (W.D. Tex. 2008) (internal quotation omitted) (emphasis added). See, e.g., Ventura Brosky, 2006 WL 3392207 (S.D. Fla. 2006) (granting a stay of civil procee