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TRICT OF FLORIDA Case No. 9:08-ev-80736-Civ-ICAM JANE DOE 1 and JANE DOE 2 I UNITED STATES JANE DOE 1 AND JANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and through undersigned
o the case, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comM5751094/law--order-commemorates-jeffrey-epsteins-taste-for- teen-hookers. The public interest in this ca
ld have been. There has long been suspicion that Jeffrey Epstein was receiving favorable treatment in the
from the 12 EFTA00209247 correspondence where Mr. Epstein's attorneys urged the United States Attorney's of
tim Unit devoted an episode to the case, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comM5751094/law--order-commemorates-jeffrey-epsteins-taste-for- teen-hookers.
ted. Continental Casualty Co. v. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, hup://gawkencom/#!5751094/law—order-commemorates-jeffity- epsteins-taste-for-teen-hookers. Al
nted. Continental Casualty Co.'. Fibreboard Corp., 4 F.3d 777, 778 (' Cir. 1993). The non-prosecution agreement in this case was signed in 2007, and Epstein entered his pleas of guilty in July 2008, in Florida circuit court. I k was sentenced by the state court, and has served his sentence. Individuals
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, hup://gawkencom/#!5751094/law—order-commemorates-jeffity- epsteins-taste-for-teen-hookers. Al
necessary" (doc. #17 at I). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. On August I, 2008, the victims filed a response to the Government's "Notice" (doe. #19), giving a proposed statement of facts
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers. http://gawker.comM5751094/law--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
ims' unredacted pleading quoting the correspondence should also be unsealed, particularly in light of the intense, international public interest in Epstein's controversial plea deal. BACKGROUND As the Court is aware, beginning 2008, Jane Doe #1 and Jane Doe #2 pursued civil litigation against Jeffrey
tween the U.S. Attorney's Office and counsel for Jeffrey Epstein to prove violations of the Crime Victims'
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
ims' unredacted pleading quoting the correspondence should also be unsealed, particularly in light of the intense, international public interest in Epstein's controversial plea deal. BACKGROUND As the Court is aware, beginning 2008, Jane Doe #1 and Jane Doe #2 pursued civil litigation against Jeffrey
tween the U.S. Attorney's Office and counsel for Jeffrey Epstein to prove violations of the Crime Victims'
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A
ane Doe No. 2 ("the victims") respectfully file this opposition to the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense
the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense attorneys concerning plea negotiations. The victims have a
peal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referre
Unit devoted an episode to it recently, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jay Epstein Taste for Teen Hookers, http://gawker.comM5751094/law--order- commemorates-jeffrey-epsteins-taste-for-teen-hookers. Also,
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
ims' unredacted pleading quoting the correspondence should also be unsealed, particularly in light of the intense, international public interest in Epstein's controversial plea deal. BACKGROUND As the Court is aware, beginning 2008, Jane Doe #1 and Jane Doe #2 pursued civil litigation against Jeffrey
tween the U.S. Attorney's Office and counsel for Jeffrey Epstein to prove violations of the Crime Victims'
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
ims' unredacted pleading quoting the correspondence should also be unsealed, particularly in light of the intense, international public interest in Epstein's controversial plea deal. BACKGROUND As the Court is aware, beginning 2008, Jane Doe #1 and Jane Doe #2 pursued civil litigation against Jeffrey
tween the U.S. Attorney's Office and counsel for Jeffrey Epstein to prove violations of the Crime Victims'
nit devoted an episode to it last month, suggesting in its plot that federal government had intervened improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen Hookers, http://gawker.comW5751094flaw--order-commemorates-jeffrey- epsteins-taste-for-teen-hookers. A
Entities connected to both Jeffrey Epstein and See Law & Order
Leon Black
PERSON
Prince Andrew
PERSON
Woody Allen
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
A. Marie Villafana
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONRoy Black
PERSONCourtney Wild
PERSONRobert D. Critton
PERSON