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As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing t
r attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." (DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms of the Protective Order, to enable
o between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by t
the Agreement has not been filed under seal with this Court, the legal authority cited by petitioners regarding sealing of documents, United States I. Ochoa-Vasque 428 F.3d 1015 (11'h Cir. 2005), is inapposite. The parties who negotiated the Agreement, the United States Attorney's Office and Jeffrey Epstein, d
As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing t
ir attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." D.E. 26 at 1. Presumably, petitioner's motion to unseal is an effort to modify the terms of the Protective Order, to enable
o between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by t
the Agreement has not been filed under seal with this Court, the legal authority cited by petitioners regarding sealing of documents, United States I. Ochoa-Vasque , 428 F.3d 1015 (11 th Cir. 2005), is completely inapposite. The parties who negotiated the Agreement, the United States Attorney's Office and Jeff
NT THIS PART OF THE VICTIMS' MOTION. In their motion (at pp. 4-6), the victims explained how the correspondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVRA case. For example, they explained that significant parts of the correspondence specifically discuss the CV
A case. For example, they explained that significant parts of the correspondence specifically discuss the CVRA and the rights of the victims in the Epstein case. The victims have therefore asked this Court to make a finding of "admissibility" regarding the correspondence, consistent with an earlier ord
orrespondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVR
dingly instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I. Ochoa-Vasque, 428 F.3d 1015 (11th Cir. 2005), it reversed an order from this Court that had sealed pleadings in a criminal case, emphasizing the importance of th
Entities connected to both Jeffrey Epstein and I. Ochoa-Vasque

Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Scarlett Johansson
PERSONthe National Alliance of Victims' Rights Attorneys
ORGANIZATION