Epstein Secrets

a agreement. See Applicants' Mem. at 18. The government counters that the carve out provision cannot be characterized as making any such accusation. See United States' Mem. at 3-4, 8-12. As noted earlier, this Court has reviewed the provisions of the information filed against Qantas, the plea agreement, the DOJ pr

would prosecute them. ev See Press Release, Qantas Airways Ltd., qvQantas Enters Plea Agreement with U.S. Govemmentev (Nov. 28, 2007) (attached to United States' Mem., Decl. of Brent Snyder, Ex. A). The applicants thus rely primarily on their argument that the %most likely implication of carve out status is

names violated Fifth Amendment or rule governing grand jury secrecy, and there was strong public interest in full disclosure of the plea agreement. U.S.C.A. Const.Amend. 5; Fed.Rules Cr.Proc.Rule 6(e), 18 U.S.C.A. [91 Federal Courts 170B 685 170B Federal Courts 170BVIII Courts of Appeals 170BVIII(F)

agreement. See Applicants' Mem. at 29. The Court recently considered substantially the same arguments of similarly situated carve out employees in Doe v. Hammond, 502 F.Supp.2d 94 (D.D.C.2007), and United States v. Korean Air Lines, Ltd., 505 F.Supp.2d 91 (D.D.C.2007), injunction pending appeal denied (D.C.Ci

nian Publishing Co. v. United States District Court, 920 F.2d 1462, 1465 (9th Cir. 1990) ("plea agreements have typically been open to the public"); United States v. Kooistra, 796 F.3d 1390, 1390-91 (11th Cir. 1986) (documents relating to defendant's change of plea and sentencing could be sealed only upon fmdi

DENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331612 EFTA_00204338 EFTA02729324 Rule 6 from disclosing plea agreement and other materials); Doe v. Hammond, 502 F. Supp. 2d 94, 99-101(D.D.C. 2007) (same). Moreover, "when the fact or document is sought for itself, independently, rather than because it w

Petitioners [Jane Doe 1 and Jane Doe 2] or other alleged victims are pursuing against Epstein, relief should be sought in that case, with notice to the United States, the other party to the Agreement. (A-6:2). These sentences offer respondents no solace. Judge Marra made crystal clear that any motion to disclose

protects disclosure of "the strategy or direction of a grand jury investigation" or "the details of the grand jury's past or future proceedings"); Doe v. Hammond, 502 F. Supp. 2d 94, 100 & n.2 (D.D.C. 2007) (requiring disclosure that "individuals are or were in the past subjects of grand jury investigation w