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

trike all references to a "non- prosecution agreement" contained in defendant, Jeffrey Epstein's ("Epstein") Motion to Stay these proceedings. Under the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule, Epstein is required to produce the written agreement (or a copy thereof) rather than s

ff, 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

ement in parallel litigation under the Crime Victim's Rights Act. Doe 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 EFTA00234762 Case 9:08-cv-80893-KAM Document 32 Entered on

trike all references to a "non- prosecution agreement" contained in defendant, Jeffrey Epstein's ("Epstein") Motion to Stay these proceedings. Under the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule, Epstein is required to produce the written agreement (or a copy thereof) rather than s

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

Jane Doe explains in her simultaneously filed motion to strike, the Court should strike all references to the contents of the agreement because of the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule. If Epstein wants to prove that a document exists with particular language that is crea

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

Jane Doe explains in her simultaneously filed motion to strike, the Court should strike all references to the contents of the agreement because of the Best Evidence Rule, Fed. R. Evid. 1002, and the principles underlying the rule. If Epstein wants to prove that a document exists with particular language that is crea