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ISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Eps
N'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective O
V-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'
the documents consist of communications between Mr. Epstein's defense counsel and the United States Attorney'
hilling effect on any settlement discussions if such discussions could later be used as admissions of liability at trial or in any other proceeding. Bank Card America, Inc. v. Universal Bank Card Systems, Inc., 203 F. 3d 477, 483 (7° Cir. 2000). One court in the -6- FOWLIR WiNrs ISURNIOT, PA • PHILLIP% POINT - W7
the documents consist of communications between Mr. Epstein's defense counsel and the United States Attorney'
ISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Eps
N'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective O
V-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'
hilling effect on any settlement discussions if such discussions could later be used as admissions of liability at trial or in any other proceeding. Bank Card America, Inc. v. Universal Bank Card Systems, Inc., 203 F. 3d 477, 483 (7° Cir. 2000). One court in the -6- FOWLIR WiNrs ISURNIOT, PA • PHILLIP% POINT - W7
ISTRICT OF FLORIDA FT. LAUDERDALE DIVISION Case No. 08-CIV-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Eps
N'S MOTION FOR PROTECTIVE ORDER AND OBJECTION TO DISCLOSURE OF CERTAIN DOCUMENTS WITH INTEGRATED MEMORANDUM OF LAW Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to a Joint Stipulation Regarding Certain Documentation files this his Motion for Protective O
V-80893-MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT, JEFFREY EPSTEIN'
the documents consist of communications between Mr. Epstein's defense counsel and the United States Attorney'
hilling effect on any settlement discussions if such discussions could later be used as admissions of liability at trial or in any other proceeding. Bank Card America, Inc. v. Universal Bank Card Systems, Inc., 203 F. 3d 477, 483 (7° Cir. 2000). One court in the -6- FOWLIR WiNrs ISURNIOT, PA • PHILLIP% POINT - W7
Entities connected to both Jeffrey Epstein and Bank Card America

Alan Dershowitz
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George W. Bush
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Bradley Edwards
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United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
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Kenneth Marra
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Paul Cassell
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Samantha Power
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Palm Beach
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Scarlett Johansson
PERSONScott Rothstein
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PERSONJaffe
PERSONSouth Flagler Drive
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