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

Doe. Such risk and speculation about possible criminal charges does not establish a real need for a stay. See Securities and Exchange Commission v. Dresser Industries, Inc., 628 F.2d 1368, 1376 (D.C. Cir. 1980) (refusing to grant a stay a civil proceeding before any indictment was returned because Fifth Amendment conce

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petitioners, Vs. UNITED STATES, Respondent. RESPONDENT'S OPPOSITION TO PETITIONERS' MOTION REQUESTING AN ORDER DIRECTING THE GOVERNMENT TO

ARRA; (2) the service of filings containing the aforementioned grand jury information shall be limited to counsel for Petitioners Jane Doe No.1 and Jance Doe No. 2 and for the government in Case No. 08-80736-CIV-MARRA, and shall be accompanied by a copy of this Order; and (3) further dissemination by any

al transcripts, `the strategy or direction of the investigation, the deliberations or questions of jurors, and the like."' Id. at 500, citin SEC v. Dresser Industries, Inc., 628 F.2d 1368, 1382 (D.C. Cir. I SDFL lOP 8.01.00 provides: "Grand jury matters, and all matters reasonably related to the original grand jury mat

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

Doe. Such risk and speculation about possible criminal charges does not establish a real need for a stay. See Securities and Exchange Commission v. Dresser Industries, Inc., 628 F.2d 1368, 1376 (D.C. Cir. 1980) (refusing to grant a stay a civil proceeding before any indictment was returned because Fifth Amendment conce

FLSD Docket 04:07)2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH

on by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc. v. United States, 596 F.2d 1231, 1237 (51h Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by t

FLSD Docket 04/08/2011 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Petitioners, vs. UNITED STATES, Respondent. UNITED STATES' RESPONSE TO JANE DOE #1 AND JANE DOE #2'S MOTION FOR FINDING OF VIOLATIONS OF TH

n by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc. v. United States, 596 F.2d 1231, 1237 (511' Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by

AM Document 48 Entered on FLSD Docket 03/21/2011 Page 4 of 42 Beach, Florida, and elsewhere. Among the girls he sexually abused were Jane Doe #1 and Jane Doe #2. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, touching of their sexual orga

n by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc." United States, 596 F.2d 1231, 1237 (5' Cir. 1979), the court of appeals observed that "[t]he decision to prosecute is largely unreviewable by the

KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 2 of 31 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-Civ- JANE DOE #1 AND JANE DOE #2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. BRUCE E. REINHART, Intervenor INTERVENOR'S MOTION FOR SANCTIONS Comes

on by the court in the internal affairs of the Justice Department would clearly constitute a violation of the Separation of Powers doctrine." Id. In Dresser Industries, Inc. v. United States, 596 F.2d 1231, 1237 (5th Cir. 1979), the court of appeals observed that tilt decision to prosecute is largely unreviewable by the