Epstein Secrets

onfidentiality provision of the settlement agreement as requested by Plaintiff. Mr. Poe, Mr. Epstein's counsel stated "I am authorized to state that Jeffrey Epstein is willing to agree not to sue plaintiff's counsel/plaintiff if the settlement agreement is disclosed to defendant Maxwell's counsel provided that (

Epstein. Initially, Plaintiff improperly conditioned production of the document by requiring that counsel for Ms. Maxwell obtain a "waiver from Mr. Epstein." Although it was not Ms. Maxwell's burden to do so, in an attempt to avoid filing this Motion, counsel for Ms. Maxwell obtained the waiver from co

COMPEL SETTLEMENT AGREEMENT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. 1

hat counsel for Ms. Maxwell obtain a "waiver from Mr. Epstein." Although it was not Ms. Maxwell's burden to do

04) ("the mere fact that the third-party defendants designated their indemnification agreement as confidential does not shield it from discovery"); Tribune Co. v. Purciglioni, 1996 WL 337277 at •3; Weissman v. Fruchtman, 1986 WL 15669,'19 (S.D.N.Y.1986) ("parties' intention that agreement remain confidenti

which of his clients is the purported victim. Accordingly,) will address facts related to , S. and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to III and In

fteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has been under federal investigation, he has not been charged in EFTA00183654 Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/20

treet, Suite 202 Hollywood, Florida 33020. Re: Jeffrey E eir m/SaVhiii: NOTIFICATION OF IDENTIFIED VICT

ve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with so

ain away its Public Records Act duties or create a "self-exemption" with a promise to third parties to keep records from disclosure to the public. Tribune Co. I. Hardee Memorial Hospital, Case No. CA-91-370, Tenth Judicial Circuit in and for Hardee County, Florida. See also Browning Walton, 351 So. 2d 3

ions, as well as other privileges and protections, over its internal deliberations in connection with the non- prosecution agreement it reached with Epstein and related discussions about victim notifications. As the Court is aware, the victims have previously-filed a substantial motion for summary judgm

nt Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872 Case 9:08-cv-80736-KAM Document 414-1 Entered on FLSD Docket 08/11/2017 Page 1 of 1 UNITED STATES DISTRICT

uite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872

ash.1975); U.S. v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir.1991); In re Kidder Peabody Securities Litigation, 168 F.R.D. 459, 468-69 (S.D.N.Y.1996); Tribune Co. v. Purcigliotti, 1997 WL 10924, *6 (S.D.N.Y. Jan. 10, 1997)). As an illustration of how the doctrine operates, this Court cited Volpe v. U.S. Ainva