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

are produced, there will be no adequate remedy. L JURISDICTION Mr. Epstein seeks to invoke the certiorari jurisdiction of this Court pursuant to Florida Rules of Appellate Procedure 9.030(bX2XA) and 9.100. Certiorari review is appropriate where, as here, an order unsealing a court record departs from the essential req

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

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 States' 5 lot 00 EFTA00231181 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 Page 6 of 10 v Degenhardt, 405 F.Supp.2d 1341, 13

are produced, there will be no adequate remedy. I. JURISDICTION Mr. Epstein seeks to invoke the certiorari jurisdiction of this Court pursuant to Florida Rules of Appellate Procedure 9.030(bX2)(A) and 9.100. Certiorari review is appropriate where, as here, an order unsealing a court record departs from the essential re

L Deanna K. Shullman James B. Lake 101 N.E. 3rd Avenue, Suite 1500 Ft. Lauderdale, Florida 33301 EFTA00233651 07/24/2009 15:22 FAX 5018059840 USA0 WPB CONFRM 07-20-'09 14:22 FROM-THOMAS & LOCICERO 8139843070 004 1-113 P003/00E-937 RESPONDENT PALM BEACH POST'S MOTION FOR APPELLATE ATTORNEYS

other instances where 5 counsel other than myself, not in the civil aspects, where 6 allegations have been made and letters have been sent by the 7 United States suggesting that there's been a violation of the 8 NPA. And under those circumstances, some notification was 9 provided. 10 THE COURT: Did it have

ROM-THOMAS & LOCICERO 8139843070 004 1-113 P003/00E-937 RESPONDENT PALM BEACH POST'S MOTION FOR APPELLATE ATTORNEYS' FEES AND COSTS Pursuant to Florida Rules of Appellate Procedure 9.400 and 9.410 and Administrative Order Number 2.303 of the Fifteenth Judicial Circuit of Florida, Respondent Palm Beach Newspapers, Inc

eed arises in a civil case Petitioners 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). Rather than seeking relief from Judge Marra in federal court, non- party E.W., a victim of Mr. Epstein, f

are produced, there will be no adequate remedy. I. JURISDICTION Mr. Epstein seeks to invoke the certiorari jurisdiction of this Court pursuant to Florida Rules of Appellate Procedure 9.030(bX2XA) and 9.100. Certiorari review is appropriate where, as here, an order unsealing a court record departs from the essential req

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

are produced, there will be no adequate remedy. I. JURISDICTION Mr. Epstein seeks to invoke the certiorari jurisdiction of this Court pursuant to Florida Rules of Appellate Procedure 9.030(bX2)(A) and 9.100. Certiorari review is appropriate where, as here, an order unsealing a court record departs from the essential re