Epstein Secrets

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 4 of 37 Doe v. Epstein 08-CV80119 Page No. 4 (a) Jane Doe Plaintiff, Jane Doe's Motion to Compel is filed at DE (194). Defendant's Response in Opposition is filed at DE (339), and the arguments set forth therein are incorporated

e, if this court rules that any of the information requested herein should be produced (e.g., Requests Numbers 12 and 13 (tax returns and passport — Jane Doe) and Request Number 1 (tax returns-Jane Doe 2-8)), it shall only do so after an in camera hearing allowing the documents to be reviewed and placed o

d in the Court's Orders (DE 242, p.4 and 462, p.2). As this Court knows, Epstein entered into a Non- Prosecution Agreement ("NPA") with the USAO for the Federal Southern District of Florida . However, the NPA does not provide Epstein with any protection from criminal investigation or prosecution other than in the Southern Di

equest as true, photographing Epstein's genitalia could potentially provide a 'lead or clue' to evidence having a tendency to incriminate. 8. In Jane Doe No. 2 v. Epstein, Case No. 08-CIV-80119 MARRA/JOHNSON, the Court sustained Epstein's Fifth Amendment objections to several interrogatories a

ate Judge Linnea R. Johnson found, "pin 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's EFTA00723224 Case No. 502008CA037319XXXXN1B AB Page 7 of 14 Office for Palm Beach County. Under the terms of

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains

OF FLORIDA CASE NO. 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defend

tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains

Y EPSTEIN, Defendant. CASE NO.: 08-80993-CIV-MARRA/JOHNSON , Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-80811-CIV-MARRA/JOHNSON JANE DOE, CASE NO.: 08- 80893-CIV-MARRNJOHNSON Plaintiff, vs. JEFFREY EPSTEIN et al, 2 EFTA00728595 Case 9:08-cv-80119-KAM Document 242 Entered on F

tion of 18 U.S.C. §2422 (Count III). In 2008. Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains

ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E

its criminal prosecution against EPSTEIN. EPSTEIN entered into a Non-Prosecution Agreement ("NPA") with United States Attorney General's Office for the Federal Southern District of Florida. The terms and conditions of the NPA also entailed EPSTEIN entering into a Plea Agreement with the State Attorney's Office, Palm Beach C

e entered into a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution. In each of these motions Plaintiff Jane Doe seeks to compel answers to certain requests for admissions, interrogatories and requests for production that were propounded on Defendant Epstein.

tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains

des Epstein's counsel's views on the limits and inapplicability of certain elements of 18 U.S.C. §2255, one of the principal causes of action in the Jane Doe cases. This opinion work product should not be disclosed when it was incorporated into heartland plea negotiations that are accorded protection und

cknowledged in the Court's Orders (DE 242 and 462). As this Court knows, Epstein entered into a Non-Prosecution Agreement ("NPA") with the USAO for the Federal Southern District of Florida. However, the NPA does not provide Epstein with gni protection from criminal investigation or prosecution in other than in the Southern

scayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300

I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Prosecution Agreement with the United States Attorney's Office (USAO) for the Federal Southern District of Florida. The terms and conditions of the Non- Prosecution Agreement also entailed the entering of a Plea Agreement with the State Attorney's Offi

69-KAM): Bruce Reinhart, LEAD ATTORNEY, Bruce . ein art, P.A., West Palm Beach, FL; Denise Kalland, Denise Kalland, P.A., West Palm Beach, FL. For Jane Doe No. 101, Plaintiff (9:09-cv-80591-KAM): Katherine Warthen Ezell, LEAD ATTORNEY, Podhurst Orseck Josefsberg et al, Miami, FL USA; Robert C. Josefsber

tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains