Epstein Secrets

ency Requet: 19-011 SDNY_GM_00331615 EFTA 00204341 EFTA02729327 CERTIFICATE OF TYPE, SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. 09/12/2019 27 CONFPITTENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331616 E

fact, the U.S. Attorney's Office has taken no position on this matter throughout the lower court proceedings and specifically informed counsel for E.W. that it had no position (A-18 at p. 7,11. 10-14.) At that hearing, the Court found that the proper procedures to initially seal the records were not

Inc. d/b/a The Palm Beach Post ("the Post") its attorneys' fees and costs in responding to this petition. JURISDICTION The Post adopts Respondent E.W.'s statement concerning jurisdiction. Insofar as this Court finds jurisdiction, the Post requests that this Court expedite its consideration of this

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen

cuments will be disclosed and there will be no adequate remedy. Petitioner, Jeffrey Epstein is referred to by proper name. Non-party interveners, E.W., B.B. and The Post are referred to as E.W., B.B. and The Post. All emphasis is supplied unless indicated otherwise. The following symbol is used: A

ith notice to the United States, the other party to the Agreement. (A-6). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen

eldt Adler, 4 day of July, 2009. 26 on this 10ffi EFTA00233638 CERTIFICATE OF TYPE, SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. 27 EFTA00233639 - Not an Official Document Page 1 of 11 Report Selection criter

not a record of the federal court. (A-6) ("First, as respondent points out, the Agreement was not filed in this 10 The Post adopts and incorporates E.W.'s arguments and analysis on this issue in addition to the arguments it sets forth herein. " The Post notes that A-3 through A-5 were not part of th

at the reply is due 10 days from service of the last-filed response. Opposing counsel has contacted counsel for respondents (William J. Berger for E.W.; Diana L. Martin for B.B.; and Deanna K. Shullman for the Post), who have all advised they have no objection to this motion. 2 EFTA00233660 -Q-~

ff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. 1st Kara Berard Rockenbach Kara Berard Rockenbach 24 EFTA00793716

t court. 2 At the March 8, 2018 hearing, University of Utah Law Professor, Paul G. Cassell, Esq., appeared pro hac vice below for non-parties L.M., E.W. and Jane Doe, on a limited confidentiality issue not before this Court. On behalf of non-parties, L.M., E.W. and Jane Doe, Mr. Cassell filed an Uno

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen

notice to the United States, the other party to the Agreement. (A-6). • Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, filed a motion in the state criminal action on May 12, 2009, seeking to intervene and unseal the non-prosecution agreemen