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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
rvene, but deferred ruling on the motions to unseal pending a later hearing (A-13). EFTA00180643 The next day, June 11, 2009, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial
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
ne, but deferred ruling on the motions to unseal pending a later hearing (A-13). 5 EFTA00231137 The next day, June 11, 2009, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial
Armed Forces of the United States, and includes a conviction or entry of a pica of guilty or nob contenders rosulting in a sanction in any stato of the United Stator or other jurisdiction. A sanction Includes, but is not limited to, a lino, probation community control, parolo, conditional release, control roloaso
Oregonian Publishing Co.'. United States District Court, 920 F.2d 1462 (9th Cir. 1990) 9 U.S. I Rosen, 471 F. Supp. 2d 651 (E.D. Va. 2007) 23 United States'. Kooistra, 796 F.3d 1390 (11th Cir. 1986) 9 State Cases Anderson I E.T., 862 So. 2d 839 (Fla. 4th DCA 2003) 8 Barron'. Florida Freedom Newspap
did not assert that he had complied with these requirements, but that he would. The Court reset the hearing for June 25, 2009. Petitioner filed a Motion to Make Court Records Confidential (A-13) on June 11, 2009. In it, Epstein cited four reasons the NPA should remain under seal: 1. to prevent a serious and imminent thre
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
did not assert that he had complied with these requirements, but that he would. The Court reset the hearing for June 25, 2009. Petitioner filed a Motion to Make Court Records Confidential (A-13) on June 11, 2009. In it, Epstein cited four reasons the NPA should remain under seal: 1. to prevent a serious and imminent thre
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
t granted both motions to intervene, but deferred ruling on the motions to unseal pending a later hearing (A-13). The next day, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial,
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
3222 CONFIDENTIAL Agency to Agency Requet: 19-011 SDNY_GM_00331621 EFTA_00204347 EFTA02729333 The next day, June 11, 2009, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial
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
ne, but deferred ruling on the motions to unseal pending a later hearing (A-13). 5 EFTA00232257 The next day, June 11, 2009, Mr. Epstein filed a Motion to Make Court Records Confidential (A-13). Mr. Epstein alleged that the documents should remain confidential to prevent a serious imminent threat to the fair, impartial
Entities connected to both United States and Motion to Make Court Records

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONJack Goldberger
PERSONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
Supreme Court
ORGANIZATIONEmmy Taylor
PERSON
Woody Allen
PERSON