3
Shared Docs
3
Same-Page
6 / 3
Mentions
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
e established that. (A-19:16). Unsealing will undeniably cause harm that cannot be remedied by an appeal at the conclusion of the case. See, e.g., Nucci v. Nucci, 987 So. 2d 135, 139 (Fla. 4 09/1212019 Pag35 CONFIDENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331786 EFTA_002045 12 EFTA027294
ng. We intend to file a motion to compel production of these materials on or about Tuesday, March 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about what is happening. We wanted to make one last effort to resolve this issue without the need for litig
arch 14 — making all of these points clearly for Judge Marra, so that he can draw his own conclusions about wh
those requests here, I would highlight one of them: Supplemental Discovery Request 3. Any emails to or from FBI employees Val Parlave, Tim Delaney, Nucci, Jason Richards, Nezbitt Kurkendall. Eliasib Ortiz, Alan Santiago regarding the prosecution (or non-prosecution) of the Epstein case, any of the Ep
hern District of Florida 1 Case No. 08-80736-CV-MARRA P-013258 EFTA00229677 99 N.E. 4th Street Mia
, 2011 12:47 PM To: Cc: Sanchez, Eduardo (USAFLS); Stamm, Edward (USAFLS); (USAFLS); Atkins a on, Karen (USAFLS); ■ Garcia, Rolando (USAFLS); Nucci, Edward (USAFLS); IMI Subject: Re: Great. Thanks Richard. From: Sent: Wedn 03, 2011 10:20 AM To: (USAFLS) Sub ect: RE: Hello Benjamin, We
Entities connected to both Kenneth Marra and Nucci

Jeffrey Epstein
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONSouthern District
LOCATION
Salt Lake City
LOCATION
New York
LOCATIONGarcia
PERSONSanchez
PERSON
Michael Douglas
PERSON
Tampa
LOCATION
James Baker
PERSON
Naomi Campbell
PERSONWright
PERSONRosen
PERSON
Los Angeles
LOCATION
Kaplan
PERSON
Toronto
LOCATION