Epstein Secrets

FILED UNDER SEAL VIA EMAIL The Honorable Robert W. Sweet United States District Court Southern Dis

proceeding such as in Subpoena Duces Tecum-relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

Cause on the following persons: The Hon. Robert W. Sweet District Judge United States District Cou

c disclosure of any sealed or redacted summary judgment materials. The OTSC is, however, incomplete because the dozens of individuals who relied on the Protective Order had no notice of the Order and have had no opportunity to respond. We interpose the following general objections: 1. All sealed and redacted summa

FILED UNDER SEAL VIA EMAIL The Honorable Robert W. Sweet United States District Court Southern Dis

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

vided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your A Mantis letter to C.W. was provi

tters that were sent to Jane Doc 41. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by the Court on August 21, 2008, EFTA00184220 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 4 of 4 beginning

1 Robert C. Jose s re gt1tIo. 040856 Katherine W. Ezell, Bar No. 114771 Podhurst Orseck, P.A. 25

s they agreed to be bound by a Protective Order. Each victim (or her attorney) was provided with notice of the Court's ruling, and several executed the Protective Order and were provided with copies of the Non-Prosecution Agreement. From the beginning, Epstein has "vigorously defended" the suits, and has filed seve

FILED UNDER SEAL VIA EMAIL The Honorable Robert W. Sweet United States District Court Southern Dis

proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by its terms to only the pretrial stages of the civil litigation, no confidential business information appears to be at issue, and counse

attached. EFTA00183583 9 /17/0S, AAV Or-11) Lc-W.:won-a , B,Ac icvDt-DFF-11c9e;e-- RE PIWAILy met&

to be bound by a Protective Order entered by the Court. If Ms. would like to review the Agreement, please let me know, and I will forward a copy of the Protective Order for her signature. As I stated in my earlier notification, please understand that neither the U.S. Attorney's Office nor the Federal Bureau of Inv

D STATES ATTORNEY DELIVERY EY FACSIMILE Kenneth W. Starr, Esq Kirkland & Ellis LLP 777 South Figue

tters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by the Court on August 21, 2008, EFTA00234651 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 4 of 4 beginni

D STATES ATTORNEY DELIVERY EY FACSIMILE Kenneth W. Starr, Esq Kirkland & Ellis LLP 777 South Figue

tters that were sent to Jane Doe #1. 12. In accordance with the Court's instructions at the status conference of August 14, 2008 and the terms of the Protective Order entered by the Court on August 21, 2008, EFTA00213129 Case 9:08-cv-80736-KAM Document 35 Entered on FLSD Docket 12/22/2008 Page 4 of 4 beginni