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hird parties. Just 1 09/12/2019 Agency to Agency Requet: 19-411 CONFPI535ENTIAL SDNY_GM_00331783 EFTA 00204509 EFTA02729494 last week, Judge Marra reviewed the non-prosecution agreement and addendum in camera in conjunction with Mr. Epstein's renewed motion to stay civil lawsuits against him (
motions to unseal. Instead, Judge Colbath stated that 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). But there is no way unsealing does not inherently violate Judge Marra's orders. 1. JURISDICTION E.W. contends there i
0331783 EFTA 00204509 EFTA02729494 last week, Judge Marra reviewed the non-prosecution agreement and addend
on agreement and addendum is not a public record. It is confidential by its terms and did not become a public record when it was filed under seal. Florida Rule of Judicial Administration 2.420 governs the disclosure of judicial records. See Morris Publ'g Group, LLC v. State, 34 Fla. L. Weekly D1101 (Fla. 1st DCA June 1, 2009). Under rule
mpiani & Vargas, P.A. (appellate counsel for petitioner) Spencer T. Kuvin of Leopold-Kuvin, P.A. (counsel for non-party intervener,..) Honorable Kenneth A. Marra (judge, Southern District of Florida) Palm Beach Newspapers d/b/a The Palm Beach Post (non-party intervener) Deanna K. Shullman of Thomas, Locic
rcement of Crime Victim's Rights Acts (A-1)." The victim also asked the federal court to allow her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Government had argued (A-4) — that the NPA was not a record of the federal court. (A-6) ("First, as respon
w her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Governm
endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu
ir identity will be indicated by their initials. 6) This Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders. 7) The disclosure of the sealed documents shall be stayed at least until June 26, 2009, at 9:00 a.m., at which time the Court wil
attempting to march up 15 the wrong hill here, your Honor. 16 This matter needs to -- has to be 17 litigated in federal court before 18 Judge Marra who has already heard hearings 19 on this matter. Now, at our last 20 abbreviated hearing two weeks ago, I told 21 you for the first time that
to be 17 litigated in federal court before 18 Judge Marra who has already heard hearings 19 on this matte
fendant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu
ir identity will be indicated by their initials. 6) This Order is in no way to be interpreted as permission to not comply with U.S. District Court Kenneth Marra's previous Orders. 7) The disdosure of the sealed documents shall be stayed at least until June 26, 2009, at 9:00 a.m., at which time the Court will
attempting to march up 15 the wrong hill here, your Honor. 16 This matter needs to -- has to be 17 litigated in federal court before 18 Judge Marra who has already heard hearings 19 on this matter. Now, at our last 20 abbreviated hearing two weeks ago, I told 21 you for the first time that
to be 17 litigated in federal court before 18 Judge Marra who has already heard hearings 19 on this matte
endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu
rcement of Crime Victim's Rights Acts (A-I)." The victim also asked the federal court to allow her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Government had argued (A-4) — that the NPA was not a record of the federal court. (A-6) ("First, as respon
w her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Governm
n response to Florida media reports of hidden cases and secret dockets, a process that has come to be known as "super-sealing." In re Amendments to Florida Rule of Judicial Administration 2.420, 954 So. 2d 16 (Fla. 2007). In adopting the interim rule, the Florida Supreme Court confirmed its commitment to safeguarding the public's constitut
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
GRAL TO THIS DEFAMATION CASE. In his motion, Dershowitz never recounts the heavy burden that he must carry to seal the records at issue. To be sure, Florida Rule of Judicial Administration 2.420 allows for the sealing of “confidential” materials. But the Rule begins by recounting the overarching principle that “t]he public shall have access t
ani & Vargas, P.A. (appellate counsel for petitioner) Spencer T. Kuvin of Leopold-Kuvin, P.A. (counsel for non-party intervener, B.B.) Honorable Kenneth A. Marra (judge, Southern District of Florida) Palm Beach Newspapers d/b/a The Palm Beach Post (non-party intervener) Deanna K. Shullman of Thomas, Locic
non-party intervener, B.B.) Honorable Kenneth A. Marra (judge, Southern District of Florida) Palm Beac
endant. MOTION TO MAKE COURT RECORDS CONFIDENTIAL Comes now the Defendant, JEFFREY EPSTEIN, by and through his undersigned attorney's, pursuant to Florida Rule of Judicial Administration 2.420 and the Administrative Orders of this Court , specifically AO 2.303 and moves this Court to treat as confidential the following records. A. A docu
Entities connected to both Kenneth Marra and Florida Rule of Judicial Administration 2.420

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONSouthern District
LOCATION
Prince Andrew
PERSONRobert D. Critton
PERSONRobert C. Josefsberg
PERSON
Virginia Giuffre
PERSONMichael J. Pike
PERSON
Donald Trump
PERSON