3
Shared Docs
3
Same-Page
4 / 3
Mentions
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
prosecution agreement with a politically- connected billionaire that has drawn considerable public attention. See, e.g., Palm Beach Post.Com, Banker Epstein Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Beach waterfront mansion and has kept company with the likes of President
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
prosecution agreement with a politically- connected billionaire that has drawn considerable public attention. See, e.g., Palm Beach Post.Com, Banker Epstein Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Beach waterfront mansion and has kept company with the likes of President
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
prosecution agreement with a politically- connected billionaire that has drawn considerable public attention. See, e.g., Palm Beach Post.Com, Banker Epstein Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Beach waterfront mansion and has kept company with the likes of President
Entities connected to both Jane Doe and Epstein Pleads

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONRobert D. Critton
PERSONSouthern District
LOCATIONScott Rothstein
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
New York
LOCATION
Lauderdale
LOCATION
Jay Howell
PERSON
Jacksonville
LOCATION
The Palm Beach Post
ORGANIZATION