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

s with the terms and conditions" and that it "outlines various obligations on the part of Epstein including, but not limited, to pleading guilty to the Indictment and Information before the 15th Judicial Circuit . . [and] waiv[ing] . . challenges to the Information filed by the [State's Attomey's Office]." Epstein Motion for

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

s with the terms and conditions" and that it "outlines various obligations on the part of Epstein including, but not limited, to pleading guilty to the Indictment and Information before the 15th Judicial Circuit . . . [and] waiv[ing] . . . challenges to the Information Wed by the [State's Attorney's Office]." Epstein Motion

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

s with the terms and conditions" and that it "outlines various obligations on the part of Epstein including, but not limited, to pleading guilty to the Indictment and Information before the 15th Judicial Circuit . . . [and] waiv[ing] . . . challenges to the Information filed by the [State's Attorney's Office]." Epstein Motio