Epstein Secrets

-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232,

09/17/2009 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 0940469, 09-80581, 09-80656, 0940802, 09-81092.

d as Exhibit 1. 5. Some 13 days later, counsel for Jane Doe No. 4 flied a motion for protective order on September 9, 2009 attempting to prohibit MrEpstein's presence at the deposition. The Defendant immediately filed a response (an Emergency Motion) on September II, 2009 requesting that the coon enter

been justified, however, under these circumstances, it was grandstanding and improper. In that the Plaintiff has stated that she voluntary went to JE's home 50 plus times without trauma until she filed a lawsuit, this brief visual encounter from a distance should not have resulted in the unilater

Entered on FLSD Docket 09/11/2009 Page 4 of 33 Page 4 the plaintiffs either directly or indirectly. However, there is no prohibition against Mr. F.pstein's attendance at a deposition where, as is reflected in the order, the communication wilt be made to the plaintiff solely through defense counsel wi

LORIDA COUNTY OF PALM BEACFI hereby Se that. On. day, hefoie me, an ACC* &if itithoiiiid to oaths and take ac/cnowledgmener, personally appeared Jeffrey E. Bpetein known to me to be the person described in and who executed the foregoing Affidavit, who wrimowledged before me that he/she executed the same, that

09-00419, 0940581, 0940656, 09-80802, 0941092. Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion F

s the intent of the Court to give the Defendant, Mr. Epstein, and his attorney an opportunity to have this Co

-80119-MARRA-JOHNSON JANE DOE NO. 2. Plaintiff JEFFREY E. EPSTEIN, Defendant. Related Cases: 08-80232, 0

edia, the Post has a right to intervene in criminal proceedings for the limited purpose of seeking access to proceedings and records. See Barron v. Florida Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988) (news media have standing to challenge any closure order); Miami Herald Publ'a Co. v. Lewis, 426 So. 2d I, 7 (Fla.

E Disposition Amount: Docket Text: SET CASE FOR 6/30/08 @ 8:30 AM FOR STATUS CHECK LEVHLD - EVENT HELD Filing Date: 30-JUN-2008 Filing Party: J EPSTEIN, JEFFREY E Disposition Amount: Docket Text: CR-DAMES. PLEAD & ADJ GUILTY SEXUAL OFFENDER. PBCJ 6 CONSECUTIVE W/06-9454AXX. 12 MOS PROB. DEFT MU

and other non-parties') motions. The Court found that the documents had not properly been sealed in the first instance and further denied Petitioner Jeffrey Epstein's Motion to Make Court Records Confidential dated June 11, 2009. 2 EFTA00184005 07/20/2009 15:23 FAX USAO WP 07-20-'09 14:22 MI PR EIO S & LOCICE

sm. EFTA00183942 THE PALM BEACH POST • WEDNESDAY, JUNE 10, 2009 Women want sex plea deal unsealed Their attorneys will ask a judge to open Jeffrey Epsteffi's records. By SUSAN SPENCER-WENDEL Palm Beach Post Staff Writer WEST PALM BEACH - When wealthy money manager Jeffrey Epstein of Palm Beach pleaded

09 Filing Party: EPSTEIN, JEFFREY E Lissposition Amount: 'Docket Text: none. 17 ORD - ORDER Filing Date: 10-JUN-2009 Filing Party EPSTEIN, JEFFREY E 'Disposition Amount: iDocket Text: (COLBATH) EVSCH SCHEDULED - HEARING EVENT Filing Date: 11-JUN-2009 Filing Party: Disposition Amount: Docke

minal case. There are civil cases pending against Mr. Epstein. 7. CURRENT AND PRIOR PROCEEDINGS IN THIS COURT:

1 months investigating Epstein, only to see then-State Attorney Barry Krischer kick the case to a grand jury Mr. Krischer backed off when one of Epsteinb gold-plated attor- neys, Alan Dershowitz, announced that some of the victims had posted MySpace comments about their alco- hol and marijuana use.

derly administration of justice" and "protect a compelling government interest." Oh, and third parties might get hurt The compel- ling interest is Epsteinb, and there is no privacy issue since the victims themselves are making the request. Palm. Beach police spent 11 months investigating Epstein, onl

stay one of the civil suits against him. (A- 11 at ¶ 6; A-18, p. 35,1. 18 - p. 36,arporating by reference Supp.A.-5 through Supp.A-6 and Supp.A.-7 I. Epstein, Case No. 08-cv-80811 (S.D. Fla. 2008) at Dkt. 33 pp. 2-5)).) 20 EFTA00183985 the federal civil litigation against Epstein. (Supp.A-5 at p. 4; S

to accomplish this purpose. Miami Herald Publ'g Co.'. Lewis, 426 So. 2d 1, 6 (Fla. 1982). This test, as well as the standard announced in Barron'. Florida Freedom Newspapers, Inc., 531 So. 2d 113 (Fla. 1988), was essentially codified in former Rule of Judicial Administration 2.051, now 2.420, which was applicable in both crim

idually, and individually, Defendants. Complex Litigation, Fla. R. Civ. Pro. 1201 Case No. 50 2009 CA 040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRA-JUDICIAL STATEMENTS AND COMMENTARY TO T

XTRA-JUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective O

mentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair trial. See State ex. rd. Miami H

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,

cause shown in order to assure a fair trial. See State ex. rel. Miami I Jerald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers, Inc. v. McCrary 520 So. 2d 32, 35 (Fla. 1988). 7. The Florida Supreme Court in McIntosh recognized that restrictions on extra- judicial comment are wit

unting the allegations: The Joinder Motion then goes on to allege — without any supporting evidence — as follows: One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-kn

Q. [Y]ou [are] aware that years before December of 2014, when the CVRA pleading was filed, that your name had come up repeatedly in connection with Jeffrey Epstein’s abuse of minors, correct? . . . A. Let me answer that question. I am aware that never before 2014, end of December, was it ever, ever alleged that I

. I know that it was alleged that I was a 11:38:46 witness to Jeffrey Epstein's alleged abuse and that was false. I was never a witness to any of Jeffrey Epstein's sexual abuse. something that you have falsely denied. on the record. The record is clear that I have And I wrote that to you, categorically denie

BY MR. SCAROLA: Q. Did you state during the same interview, the CNN Don Lemon interview: "She has said that Bill Clinton was with her at an orgy on Jeffrey's island"? A. I did state that, yes. Q. Was that statement intended as fact, opinion, or was it intended as rhetorical hyperbole? MR. SCOTT: Do yo

that that testimony, under oath, of your friend, Mr. Epstein's staff person, exonerates yon? A. First, a litt

t proceedings. A trial is a public event, and the filed records of court proceedings are public records available for public examination.” Barron vy. Florida Freedom Newspapers, Inc., 531 So.2d 113, 118 (Fla. 1988) (emphasis added). In light of this presumption of openness, “[t]he burden of proof in [closure] proceedings shall alw

attached), you are quoted as making the following statements: 1. "We would be very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where, how frequently and the ex

very keen to speak with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where, how frequently and the extent to which it involved the transport of children inside and outside t

with Prince Andrew, given his relationship with Jeffrey Epstein." 2. "We want to obtain additional deta

ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,

cause shown in order to assure a fair trial. See State ex. rel. Miami Herald Publishing Co. v. McIntosh, 340 So. 2d 904, 910 (Fla. 1976); see also Florida Freedom Newspapers, Inc. v. McCrary, 520 So. 2d 32, 35 (Fla. 1988). The Florida Supreme Court in McIntosh recognized that restrictions on extrajudicial comment are within t

t proceedings. A trial is a public event, and the filed records of court proceedings are public records available for public examination.” Barron vy. Florida Freedom Newspapers, Inc., 531 So.2d 113, 118 (Fla. 1988) (emphasis added). In light of this presumption of openness, “[t]he burden of proof in [closure] proceedings shall alw

unting the allegations: The Joinder Motion then goes on to allege — without any supporting evidence — as follows: One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend of Epstein’s and well-kn

Q. [Y]ou [are] aware that years before December of 2014, when the CVRA pleading was filed, that your name had come up repeatedly in connection with Jeffrey Epstein’s abuse of minors, correct? . . . A. Let me answer that question. I am aware that never before 2014, end of December, was it ever, ever alleged that I