Epstein Secrets

nterests in full disclosure of the plea agreement-the right of the public and the press to have access to court proceedings ( see Washington Post v. Robinson, 935 F.2d 282, 288 (D.C.Cir.1991)) and the victims' right of access to the terms of a plea agreement under the Crime Victim Rights Act, 18 U.S.C. §

rrently are, subjects of an ongoing grand jury investigation. Applicants' Mem. at 3-4, 9-16. The Court considered substantially the same argument in Hammond, and concluded that qv there is no cnecessary implicationgv from the carve out provision as to a grand jury *142 investigation.c Hammond, 502 F.Sup

ggs rule well beyond the grand jury context, and ordered other court filings and records naming an unindicted co-conspirator sealed and struck.em). Hammond, 502 F.Supp.2d at 101-02; Korean Air Lines, 505 F.Supp.2d at 93-94. The applicants contend that the disclosure of their names in the carve out provi

argument in Hammond, and concluded that qv there is no cnecessary implicationgv from the carve out provision as to a grand jury *142 investigation.c Hammond, 502 F.Supp.2d at 100. Hence, although qv DOJ's comments do indeed indicate that culpability is one possible reason for carving out an employee fro

ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD

gs. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M

s such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various Epstein civil cases. On information and belief

GENATT,STEPHEN A EMMETT,PAUL ROBINSON,EDWARD WRIGHT,ROSITA H MESSING,JOAN

2100 CONDO ASSOC INC CLARK,JAMES H HAMMOND,DANA TIGANI JR,JAMES V NEDERLANDER,

ic and Spatial Structures of Dynamical Systems. KNAW Verhandelingen. Afel.. Amsterdam. pp. 183-231. Nancy. N.L.. Peso, M.. Even. N.. Barron. A.B.. Robinson. G.E.. 2013. Altivistic behavior by egg-laying worker honeybees. Curt. Biol. 23. 1574-1578. Nonacs, It. 2006. Nepotism and brood reliability in the

ny's rate of production of offspring—may play a role in explaining evolution of worker policing (Foster and Ratnieks 2001a,c: Hartmann et al_ 2003; Hammond and Keller. 2004; Wenseleers and Ratnieks. 2006b; Helantera and Sundstrom. 2007; Khila and Abouheif. 2008; Zanette et al. 2012). Yet reliable pub-