Epstein Secrets

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifiedo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

nited States, Case No. 08-80736-CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe # 2 54 EF

urate information came to be made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincirely, BE/sg Brad Edwards SECTS KADRDWARDSLAW COM EFTA00230161 Case 9:08-cv-80736-KAM Document 50-2 Entered on FLSD Docket 03/21/2011 Page 1 of 2 UNITED STATES DISTRICT

10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 24i 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougl

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifiedo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: bradarloatht

urate information came to be made a part of the record and the extent to which Mr. Epstein, through his attorneys, was culpable. Sincerely, BE/sg Brad Edwards 2028 minnow 8TRXIT,8171T11 202, HOLLYWOOD, FLORIDA 33020 OFFICE: 954-414-8033/305-935-2011 FARz 954 - 924 - 1530/305-955-4227 BRORADIDWARDSLAW.0

cy seeks to protect . . unindicted individuals from the anxiety, embarrassment, and public castigation that may result from disclosure.") (cited in Steinger). 5 08-80736-CV-MARRA 000941 EFTA00230765 e•;;S",:%%::: - - • /len" Case 9:08-cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Pag

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

ts that the victims have offered. DATED: March 21, 2011 Respectfully Submitted, l Bradley J. Edwards adley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

n that we believe is material to the victims' CVRA case — a limited amount of information that could be swiftly located by your Office." Letter from Bradley J. Edwards & Paul G. Cassell to Wifredo A. Ferrer, Mar. I, 2011. The victims have, for example, requested that the U.S. Attorney's Office provide to them unreda

r Court, 464 U.S. 501 (1984)] so as to warrant scaling, and provides good cause under the common-law access balancing test to preclude disclosure. Steinger, 626 F. Supp. 2d at 1235-36 (brackets in original omitted). See also In re Petition of American Historical Assn, 62 F. Supp. 2d 1100, 1103 (S.D.N.Y.

tes District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehr

Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E-mail: brad@pathtoj

10 of access is not absolute and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States v. Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand jury system depends upon the secrecy of grand jury proceedings," Dougla

of the June 12, 2009 hearing on Mr. Epstein's renewed motion to stay the civil cases pending in front of federal Judge Marra, Jane Doe's attorney, Brad Edwards, also counsel for respondent E.W., advised Judge Marra that he had filed the non-prosecution agreement "under seal in your court" in "Jane Doe 1 an

eement "under seal in your court" in "Jane Doe 1 and 2 vs. United States of America" (EWA at 5). Mr. Epstein's counsel advised Judge Colbath of Mr. Edwards' sealed filing in federal court at the June 25, 2009 hearing: "June 12th, Mr. Edwards advised Judge Marra that he had, in fact, filed a nonprosecut

ly entitled to protection, as there may have been accusations made for which no indictment was returned." Id. at 218 n.8; see also United States v. Steinger, No. 08-21158-CR, 2009 WL 1674798, at *3 (S.D. Fla. Apr. 28, 2009) (discussing the "devastating consequences" from revealing names of "those person