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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did not issue." GLL GmbH & Co. Messeturm KG v. La Vecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. Fir

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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did hot issue." GLL GmbH & Co. Messeturm KG v. La Vecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. Fir

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

f criminal proceedings, "a party bears the heavy burden of demonstrating that there would be a clear case of hardship if a stay did not issue." GLL GmbH & Co. Messeturm KG1 LaVecchia, 247 F.R.D. 231, 233 (D. Me. 2008) (internal quotations omitted). Epstein's motion fails for at least three reasons. First,