Epstein Secrets

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

on of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 6,7. Moreover, the right to privacy encompasses at least two different kinds o

010 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I --------------- Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,

OF THE MAGISTRATE'S ORDER DATED JUNE 1, 2010 (DE 555), WITH INCORPORATED OBJECTIONS 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

TED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

ion of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 8. If disclosure is made, this court should then determine what portions of th

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

on of confidential information without conducting an in camera review to determine whether the assertion of privilege is valid. See Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So. 3d 620, 622 (Fla. 4th DCA 2009). 7. Moreover, the right to privacy encompasses at least two different kinds of

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

determine whether the requesting party establishes a need for the information that outweighs the privacy rights of the non-party." Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 14 EFTA00582662 So.3d 620, 622 (Fla. 4th DCA 2009). Assuming that the testimony and information sought in the sub

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

determine whether the requesting party establishes a need for the information that outweighs the privacy rights of the non-party." Westco, Inc. v. Scott Lewis' Gardening & Trimming, Inc., 26 So.3d 620, 622 (Fla. 4th DCA 2009). Assuming that the testimony and information sought in the subpoena is, in fact,