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

er 25, 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to; Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 Michael R. Tein, Esquire Lewis 'rein, P.L. 3059

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

ber 16. 2008 a true and correct copy of the above and foregoing document is being provided by United States mall to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, PA. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 [email protected] Michael R. Tein, Esquire L

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

ber 16. 2008 a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, Florida 33401 [email protected] Michael R. Tein, Esquire L

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

ber 6. 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Florida 33401 Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue Sui

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. Cl United States v. Ochoa-Masque, 428 F.3d 1015 (11th Cir. 2005) (to justify sealing of court records "a court must articulate the overriding interest along with fin

er 25, 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. Michael R. Tein, Esquire Lewis Tein, P.L. Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Critton. Burman.

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

er 25, 2008, a true and correct copy of the above and foregoing document is being provided by United States mail to: Jack Alan Goldberger, Esquire Atterburty, Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 Milorida 33401 Michael R. Tein, Esquire Lewis Tein, P.L. 3059 Grand Avenue S