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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-8109
ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua
-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0
e 1400 FL 33401-5012 Counsel for Defendant Jefj•ey Epstein Brad Edwards, Esq. Fanner, Jaffe, Weissing, Edw
upon review of the book or journal by Epstein's criminal lawyer, Jack Goldberger, Esq., it appeam thc "book" or "journal" doca contain the namea of Epatcin's busiftetts-asseeimes-antl-ether--highlr eetifttleyttitt4-eemtitereittilt settstitive-infermatiett-thttt-wett4d he entirely irrelevant to thio act
ess. See Seattle Times Co. v. Rhinehart, 467 U.S. at 32-34, (pretrial interrogatories and depositions "were not open to the public at common law"); Gannett Co. v. DePasquale 443 U.S. 368, 396, 99 S.Ct. 2898, 2914, 61 L.Ed.2d 608 (1979) (Burger, C.J., concurring) ("[I]t has never occurred to anyone, so far
uly 10.2020.2:06 AN1 • I I mm mod GNsialne Maxwell behind ban as new details emerge Jeffrey Epstein's ex-gw1.0. Wenta. groom and 11 VI • J.66, Epstem's sex aunts by he@ng him Ghislaine Maxwell, a British socialite and longtime companion of disgraced financier Jeffrey Epstein, is facing a reckonin
ficant facts since briefing closed on the first round of review of sealed materials. After many months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in his criminal activities, the government secured an indictment against her. On July 2, one day after
his apartments in New York City — near his own townhouse, where he would allegedly rape her the next year. MAIM Feds finally start investigating Jeffrey Epstein's gal pal Ghislaine Maxwell "In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New York. Epstein asked 17-year-old Doe if sh
TA00075089 ca3FtsVrit5164 Get. PtiftitPtiktivektA8Siig W*40441319 Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously (the plaintiff) who was 17 at this point. (Title 18, Unit
months of relentless negative media coverage of Mr. Epstein and allegations that Ms. Maxwell was involved in
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 1 of 11 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON -------------~/ Related cases: 08-8
ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua
ROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h
ess. See Seattle Times Co. v. Rhinehart, 467 U.S. at 32-34, (pretrial interrogatories and depositions "were not open to the public at common law"); Gannett Co. v. DePasguale, 443 U.S. 368, 396, 99 S.Ct. 2898, 2914, 61 L.Ed.2d 608 (1979) (Burger, C.J., concurring) ("[I]t has never occurred to anyone, so far
press conference announcing the charges. `Maxwell enticed minor girls, got them to trust her and then delivered them into the trap that that she and Epstein had set for them. She pretended to be a woman they could trust, all the while she was setting them up to be sexually abused by Epstein and, in some
ively prejudicial statements following Ms. Maxwell's arrest:5 'The reality of how this organization worked was that 99.9% of it was orchestrated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported t
York, NY 10007 Haddon, Morgan and Foreman, t.c Jeffrey PagHue° 150 East 10th Avenue Denver, Colorado 8
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
York, NY 10007 Haddon, Morgan and Foreman, t.c Jeffrey PagHue° 150 East 10th Avenue Denver, Colorado 8
press conference announcing the charges. `Maxwell enticed minor girls, got them to trust her and then delivered them into the trap that that she and Epstein had set for them. She pretended to be a woman they could trust, all the while she was setting them up to be sexually abused by Epstein and, in some
ively prejudicial statements following Ms. Maxwell's arrest:5 'The reality of how this organization worked was that 99.9% of it was orchestrated for Jeffrey Epstein's personal sexual satisfaction. So to the degree that um there was a main facilitator that started the whole thing, it was Ghislaine. 3 A purported t
afeguard the due process rights of the accused, has "an affirmative constitutional duty to minimize the effects of prejudicial pretrial publicity." Gannett Co. v. DePasquale, 443 U.S. 368, 378 (1979). This District has given effect to this Sixth Amendment right through Local Criminal Rule 23.1. Accordingly,
Entities connected to both Jeffrey Epstein and Gannett Co.

Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Michael Cohen
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Alfredo Rodriguez
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATION
Bill Richardson
PERSON
Scarlett Johansson
PERSON