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nd 2007, defendant Jeffrey Epstein (a billionaire with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm 2 The Court should accept all these facts as true for reasons the victims explain in their contemporaneously-filed Jane Doe #1 and Jane Doe #2's Mo
oner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense " 18 U.S.C. § 3553(a)(2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States v.
on for Permission to Disclose Grand Jury Material" for the following reasons: 1. The Application contains information regarding proceedings before West Palm Beach Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. 2. Pursuant to Rule 6(eX6), "[r]ecords, orders,
be negated because the Government's communications facilitated "misconduct" by depriving the victims of their rights under the CVRA. (DE 265 at 6). The Eleventh Circuit has recognized that "[t]he crime-fraud exception presents one of the rare and extraordinary circumstances in which 15 EFTA00086459 Case 9:08-cv-
Entered on FLSD Docket 07/1; U.S. Department of Justice United States Attorney Southern District of Florida 500 South etustrahan Ave., Suite 400 West Palm Coach. FL 3340! ($61) 820471F Facsimile: (56!) 820.8777 August I I, 2006 DELIVERY BY HAN2 Miss Teal Re: Crime Victims' and Witnesses' Righn D
tioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.C. § 3553(aX2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I O
Entities connected to both West Palm and The Eleventh Circuit

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Kenneth Marra
PERSONJane Doe
PERSON
West Palm Beach
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Lesley Groff
PERSON
Alan Dershowitz
PERSONSouthern District
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
A. Marie Villafana
PERSON