Epstein Secrets

was entitled to see the nonprosecution agreement in cases other than the one immediately before it. Back in state court, one of Epstein's victims, E.W., intervened in the criminal case and moved to vacate the order sealing the nonprosecution agreement. (A-10). E.W. argued that the agreement was imp

that it is pointless to keep the document sealed in state court. (A-11, p. 4). The trial court held a hearing on the motions to intervene filed by E.W. and the Post. (Respondent B.B.'s Appendix ("RA")). The judge advised the parties that it did not appear the proper procedures were followed with re

ner, L.T. No. 20098CF009381A vs. STATE OF FLORIDA, Respondent. NOTICE OF APPEARANCE PLEASE TAKE NOTICE that Diana L. Martin of the law firm of LEOPOLD—KUVIN, P.A., hereby enters an appearance in the above-styled case as co-counsel of record on behalf of Respondent B.B. (non-party intervener below).

s: 1. EW is filed a motion to vacate the agreed order sealing records and to unseal the nonprosecutuion agreement and addendum in this file. Also, E.W. opposed defendant's motion to unseal said records. E.W.'s motion was granted and defendant's was denied at hearing on June 26, 2009. 2. E.W. is en

ted ha, and for that reason 2 2 were not going forward. 3 On behalf of BB: 3 MR. CRITTON: I didn't see any contact • ADAMS. CAMINO, ESQUIRE LEOPOLD KUV1N S 2925 PGA Boulevard 4 5 because 1, obviously, was not out there. We started at about — when you came in it was Suite 200 6 approximat

quy, they were an inducement for defendant to enter into his guilty pleas, They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court.

South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suitk,Q0 est Palm Beach, FL 33401. LEOPOLD—KUVIN, P.A. 2925 PGA Boulevard Suite 200 alm Beach Garde i 410 T. KUVIN, Esq. ar No.: 089737 Page 3of 3 EFTA00180827 Page 2 of I I Westla

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

e? 18 A. Yes. I guess you could say that. 19 Q. And who else was there? 20 A. My Aunt fia 21 Q. And what was that meeting about? 22 MR. LEOPOLD: Objection. That calls for 23 attorney/client privilege. 24 BY MR. TEIN: 25 Q. What discussions did you have with Ph. Fax. 1655 Palm Beach

quy, they were an inducement for defendant to enter into his guilty pleas. They are proper objects of discovery. However, unless they are unsealed, E.W. is unable to obtain them or utilize them in her case. 7. Pursuant to Rule 2.420(dX5), the Court must hold a hearing on this motion in open court.

nue South, Suite 1400, West Palm Beach, FL 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suit est Palm Beach, FL 33401. LEOPOLD—KM/TN, P.A. 2925 PGA Boulevard Suite 200 ens, FL 33410 (facsimile) T. KUV1N, Esq. ar No.: 089737 Page 3of 3 EFTA00231327 Page 2 of I I Wds