Epstein Secrets

er a victim under the CVRA. It should be emphasized that the CVRA "was designed to be a 'broad and encompassing' statutory victims' bill of rights." United Slates I 5 EFTA00180684 Case 9:08-ov-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 Degenhardt, 405 F.Supp.2d 1341, 1342 (D. Ut

thers. In September 2008, Jane Doe 1 and Jane Doe 2 filed motions in the federal action to unseal the non-prosecution agreement and addendum (A-3). The United States Attorney's Office opposed disclosure noting its confidentiality provision, the movant's right to access the agreement, and Judge Marra's protective

place nee supplement the filing and service of pleadinset or other papers a by local nolcsof cant. This form, approved by iheJudklal Contaeneeor the Uniled Sates in September 1974, Is rewired for the use or the Clerk theolyil e cad dwa. IS CI INSTRUCTIONS ON THE REVERS( Of THE FOAMS NOTICE: Altorneys MUST In

he first place, See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

lated civil suits), the burden should fall on those who would keep the document sealed to show cause for doing so. No good cause has yet been shown. CI United States v. Ochoa-Vasque, 428 F.3d 1015 (Ill" Cir. 2005) (to justify sealing of court records "a court must articulate the overriding interest along with fin

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-pros

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (li ' Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

FILED by /g..3 D.C. JUL 0 9 2008 STEVEN M. LARDAORE CLERK U.S. DIST. CT. S.D. Of FLA. • wee. DECLARATION OF A. MARIE VILLAFARA IN SUPPORT OF UNITED STATES' RESPONSE TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT QF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771 I. I, A. Marie Villafafia, do hereby declare

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-pros

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11'h Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United Slates, eitherunderseal or otherwiseOrr August 14, 2008, this Court held a telephonic hearing to discuss petitioners' request for a copy of the non-prosecu

arties. Since the Agreement has not been filed under seal with this Court, the legal authority cited by petitioners regarding sealing of documents, United States'. Ochoa- Vasque 428 F.3d 1015 (11th Cir. 2005), is inapposite. The parties who negotiated the Agreement, the United States Attorney's Office and Jeff

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown'); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act

se the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either wider seal or otherwise, On August 14, 2008, this Court ?mid a telephonic hearing to discuss petitioners' request for a copy of the non-pros

he first place. See Fed. R. Civ. P. 26(c) (allowing for entry of a protective order upon motion for a party "for good cause shown"); see also In re Alexander Grant & Co. Litigation, 820 F.2d 352, 356 (11th Cir. 1987) ("good cause" for a protective order "generally signifies a sound basis or legitimate need to take judicial act