Epstein Secrets

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

d, "Request to Make Circuit and County Court Records in Non-Criminal Cases 9 EFTA00231141 Confidential") do not apply to criminal cases. See Ha. R. Jud. Admin. 2.420, 2007 Court Commentary ("New. subdivision (d) applies to motions that seek to make court records in non-criminal cases confidential i

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

isclosure of matters protected by a common law or privacy right not generally inherent in the specific type of proceeding sought to be closed." Ha. R. Jud. Admin. 2.420(c)(9)(A)(vi) (emphasis added). Epstein argues disclosure of a plea agreement is not generally inherent in a state court plea hearing

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

le 2.420(d) (titled, "Request to Make Circuit and County Court Records in Non-Criminal Cases Confidential") do not apply to criminal cases. See Ha. R. Jud. Admin. 2.420, 2007 Court Commentary ("New subdivision (d) applies to motions that seek to make court records in 09/1212019 Wge 3251 CONFIDENTIAL

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

les of judicial administration provided that court records "shall be confidential" if a court has determined that confidentiality is required. Ha. R. Jud. Admin. 2.420(c)(9). Rule 2.420(c)(9) provides: —0)-Exemptionsr-The following records of the judicial branch shall be confidential: (9) Any court