Epstein Secrets

onfidentiality clause, precluding it from EFTA00180632 being disclosed to third parties or made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to third parties. 3. Fifteenth Judicial Circuit Judge Deborah Pucillo ordered Mr. Epstein's attorney

he court. (A-16:2; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A-16:3). Subsequent to this oral ruling, Mr. Epstein provided the court with a Motion for Stay (A-14). The court stayed disclosu

frey Epstein is hereby ordered to be unsealed. DONE AND ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this day of , 2008. KENNETH A. MARRA UNITED STATES DISTRICT COURT Copies furnished to: all counsel of record EFTA00180700 a I EFTA00180701 Case 9:08-cv-80736-KAM Document 29 E

made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

onfidentiality clause, precluding it from EFTA00232246 being disclosed to third parties or made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to third parties. 3. Fifteenth Judicial Circuit Judge Deborah Pucillo ordered Mr. Epstein's attorney

he court. (A-16:2; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous a d‘rs." (A-16.3). Subsulticnt to this oral ruling, M. Epstein provided the court with a Motion for Stay (A-14). The court stayed disclosu

py of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, 1 certify that I have reviewed and agree to be bound by

made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

cases are pending against Mr Epstein in Florida slate and federal courts In May 2009, the related federal court cases were consolidated before Judge Kenneth Marra for discovery and procedural purposes. Judge Marra directed that witnesses common to the multiple cases would be deposed only once. Undersigned cou

deral courts In May 2009, the related federal court cases were consolidated before Judge Kenneth Marra for discovery and procedural purposes. Judge Marra directed that witnesses common to the multiple cases would be deposed only once. Undersigned counsel understands from conversations with counsel for

eth Marra for discovery and procedural purposes. Judge Marra directed that witnesses common to the multiple ca

or will lead to the discovery of relevant information, a trial court has discretion to deny the irrelevant discovery. Allstate Insurance Company v. Langston 655 So. 2d 91, 95 (Fla. 1995): Residence Inn by Marriott v. Cecile Resort, Ltd. 822 So. 2d 548, 550 (Fla. 5th DCA 2002) (agreeing that carte blanch

1 CONFliteINTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331640 EFTA 00204366 EFTA02729352 motion of any party (A-7:40). Federal Court Judge Marra has twice denied public access to these documents. Mr. Epstein seeks certiorari review on an emergency basis.2 The court stayed disclosure until n

he court. (A-16:2; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A-16:3). Subsequent to this oral ruling, Mr. Epstein provided the court with a Motion for Stay (A-14). The court stayed disclosu

352 motion of any party (A-7:40). Federal Court Judge Marra has twice denied public access to these document

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement a

onfidentiality clause, precluding it from EFTA00231126 being disclosed to third parties or made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to third parties. 3. Fifteenth Judicial Circuit Judge Deborah Pucillo ordered Mr. Epstein's attorney

; A-18:43). The court ruled that "[t]his Order is in no way to be interpreted as 6 EFTA00231138 permission to not comply with U.S. District Court Kenneth Marra's previous Orders." (A-16:3). Subsequent to this oral ruling, Mr. Epstein provided the court with a Motion to Stay (A-14). The court stayed disclosur

made part of any public record. Federal District Judge Marra has twice ordered the documents not disclosed to

from the essential requirements of law and causes material injury that cannot be remedied on appeal after final judgment. See Allstate Ins. Co. v. Langston, 655 M. 2d 91, 94 (Fla. 1995). This Court should exercise its certiorari jurisdiction to quash the order unsealing the non-prosecution agreement an

f the NPA through the federal proceedings before Judge Marra (see 's response to the petition filed herewith

2,18 27:24 29:1,16 34:5 38:12,13 39:11 41:14 making 42:7 43:9,24 44:5 man 12:24 mandate 7:24 8:20 8:21 10:3 many 20:23 31:3 42:1 2:14 4:9 MARRA 1:11 Martin 2:17 4:16 Master 21:2 32:16 matter 20:15 37:13 44:19 matters 21:11 may 3:3 5:1 7:2,10 9:9,12 10:4,17 11:19 13:17,18 14:18 15:12

l injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal. Allstate Ins. Co.'. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co. I. EFTA00184085 McGuire, 670 So.2d 153 (Fla. 4th DCA 1996); see, Menke' Broward School Bd, 916 So.2d 8

aw enforcement have conducted investigations of The undersigned attorneys were given a copy of the NPA through the federal proceedings before Judge Marra (see E.W.'s response to the petition filed herewith), but, inexplicably, undersigned was not provided a copy of the Addendum. We have never seen it

f the NPA through the federal proceedings before Judge Marra (see E.W.'s response to the petition filed herew

l injury to the petitioner throughout the remainder of the proceedings below, effectively leaving no adequate remedy on appeal. Allstate Ins. Co.'. Langston, 655 So.2d 91, 94 (Fla. 1995); Barad & Co.'. EFTA00233732 McGuire, 670 So.2d 153 (Fla. 4th DCA 1996); see, Menke'. Broward School Bd, 916 So.2d 8

Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOM

urdensome and over- broad, but also constituted a fishing expedition un- related to the issues raised by the pleadings. In Allstate Insurance Co. v. Langston, 655 So.2d 91, 95 (Fla.1995), the supreme court held that certi- orari was available and should be used to quash an order "to the extent that it pe

to protect a non-party from discovery that would result in “annoyance, embarrassment, oppression or undue burden or expense...” Al/state Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 2003) (Florida Supreme Court overturning denial of protective order and holding that “[d]iscovery of certain kinds of inform

ral part of the civil proceeding, particularly when the condition is asserted as an issue by the party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE RECORDS BE SEALED IN THIS CASE. Dershowitz also appears to contend that Judge Marra’s order striking s

he party seeking closure” (emphasis added)). Il. JUDGE MARRA’S ORDER IN HIS CASE DOES NOT REQUIRE THAT THE REC