Epstein Secrets

ng the information that you have in that regard voluntarily, as opposed to us having to conduct formal discovery to get it. As you also know, Judge Marra has recently ordered discovery to proceed in this case. We obviously would like for that process to go as smoothly as possible and want to avoid be

E DOE, et al., 6 Plaintiffs, JUNE 12, 2009 7 VS. 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Bou

ct formal discovery to get it. As you also know, Judge Marra has recently ordered discovery to proceed in this

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

uct formal discovery to get it As you also know, Judge Marra has recently ordered discovery to proceed in this

ing the information that you have in that regard voluntarily, as opposed to us having to conduct formal discovery to get it As you also know, Judge Marra has recently ordered discovery to proceed in this case. We obviously would like for that process to go as smoothly as possible and want to avoid be

E DOE, et al., 6 Plaintiffs, vs. JUNE 12, 2009 7 8 JEFFREY EPSTEIN, 9 Defendant. 10 11 TRANSCRIPT OF MOTION HEARING BEFORE THE HONORABLE KENNETH A. MARRA, 12 UNITED STATES DISTRICT JUDGE APPEARANCES: 13 14 FOR THE PLAINTIFFS: ADAM D. HOROWITZ, ESQ. Mermelstein & Horowitz 15 18205 Biscayne Bou

ting criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and to voluntari

uired under Fed. R. Civ. P. 26(a)( I )(A). DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of March, 2011. KENNETH A. MARRA United States District Judge 2 EFTA00208474

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio v. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law th

uired under Fed. R. Civ. P. 26(a)( I )(A). DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of March, 2011. KENNETH A. MARRA United States District Judge 2 EFTA00212474

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

uired under Fed. R. Civ. P. 26(a)( I )(A). DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of March, 2011. KENNETH A. MARRA United States District Judge 2 EFTA00235222

UTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 1. UNITED

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

te court and some in federal court. Other identified victims have also filed suit, and a number of those lawsuits are consolidated in front of Judge Marra in the U.S. District Court. In connection with those federal civil suits, a subpoena was issued to Alfredo Rodriguez to appear for a deposition and

er of those lawsuits are consolidated in front of Judge Marra in the U.S. District Court. In connection with t

payments, promises of immunity, leniency, preferential treatment, or other inducements made to prospective Government witnesses, within the scope of Giglio vs. United States 405 U.S. 150 (1972), and Napue vs. Illinois 360 U.S. 264 (1959). E. The Government shall supply the defendant(s) with a record o

requited under Fed. R. Civ. P. 26(eXI)(A). DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of March, 2011. KENNETH A. MARRA United States District Judge 2 EFTA00230163 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 1 of 9 UNITED STATES DIST

ments there. 3 EFTA00230175 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 4 of 10 On October 20, 2010, this Court (Marra, J.), entered an order (Doc. #222) remanding to the magistrate judge to give Epstein an opportunity to file a reply brief. On November 1, 2010, Eps

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio v. United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law th

requited under Fed. R. Civ. P. 26(aXI)(A). DONE AND ORDERED in Chambers at West Palm Beach, Palm Beach County, Florida, this day of March, 2011. KENNETH A. MARRA United States District Judge 2 08-80736-CV-MARRA 000917 EFTA00230741 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page

CV-MARRA 000929 EFTA00230753 Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 4 of 10 On October 20, 2010, this Court (Marra, J.), entered an order (Doc. #222) remanding to the magistrate judge to give Epstein an opportunity to file a reply brief. On November 1, 2010, Eps

1976) (same), on issue of possible violations of their rights under CVRA and remedy for such violations, including any impeachment information under Giglio i United States, 405 U.S. 150 (1972). 2. The parties shall make every possible effort in good faith to stipulate to all facts or points of law the

UTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. U

l her as a prosecution witness, the government would have been obligated to disclose her prior exculpatory statements as impeachment material under Giglio v. United States, 405 U.S. 150 (1972). While petitioners attempt to rehabilitate Jane Doe 2 by relying upon theories of victimization, to explain h

UTHERN DISTRICT OF FLORIDA CASE NO.: 10-80015-CR-Marra/Hopkins UNITED STATES OF AMERICA, Plaintiff, v

payments, promises of immunity, leniency, preferential treatment, or other inducements made to prospective Government witnesses, within the scope of Giglio vs. United States, 405 U.S. 150 (1972), and Napuc vs. Illinois, 360 U.S. 264 (1959). E. The Government shall supply the dcfcndant(s) with a record