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

0811-KAM Document 55 Entered on FLSD Docket 04/09/2609 Page 3 of 6 C.M.A. vs. Epstein, et al. Case No.: 08-CV-80811-CIV-MARRAMOHNSON Plaintiffs Motion for Extension of Time in Which to File a Response to Defendant's Motion to Stay And Or Continue 6. The requested extension is fair and reasonable under the circumstance

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO.2, Plaintiff, CASE NO.; 08-CV-80119-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.3, CASE NO.; 08-CV-80232-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO.4, CASE NO.; 08-CV-80380-MARRA/JOHNSON Plain

RRA/JOHNSON Plaintiff, JEItItEY EPSTEIN, Defendant. PROPOSED ORDER This matter came before the Court on Defendant, JEFFREY EPSTEIN's, Unopposed Motion for Extension of Time to file Reply to Plaintiffs' Jane Does 2-7 EFTA00727465 Case 9:08-cy-80119-KAM Document 123-2 Entered on FLSD Docket 05/29/2009 Page 4 of 5 Re

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2009 Carolyn Edwards Bradley Edwards All depos in Jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

ected by privacy rights 01808-01809 09/10/2009 Paul Cassell Bradley J. Edwards Activity in case 9:08-cv-80119- KAM Doe v. Epstein - Order on Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of th

vilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 01080-01081 06/22/2009 Jane Doe brother Attorney/Client privilege and/or work product 01077 05/28/2009 1 1 3 Doe family member Attorney/Client privilege and/or work product

f the admissible evidence; protected by privacy rights 01808-01809 09/10/2009 I Activity in case 9:08-cv-80119- KAM Doe v. Epstein - Order on Motion for Extension of Time to File Response/Reply/Answer Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of th