Epstein Secrets

rsuant to the terms of a federal order issued by Judge Marra of the Southern District of Florida: As Mr. Epst

ble to obtain the sealed nonprosecution agreement from the United States Attorney's Office pursuant to the terms of a federal order issued by Judge Marra of the Southern District of Florida: As Mr. Epstein's counsel stated at the June 25, 2009 hearing in front of Judge Colbathill., as an alleged vict

you are aware, the Agreement contains a confidentiality provision. Based upon a lawsuit filed by some of Mr. Epstein's victims, U.S. District Judge Kenneth Marra has issued a Protective Order requiring the U.S. Attorney's Office to provide copies of the Agreement to certain individuals under certain circumsta

n's petition for writ of certiorari with the attached letter to Respondent ■. from the United States Attorney's Office. Dated: August 5, 2009 By: Diana L. Martin Florida Bar No. LEOPOLD-KUVIN, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens. FL 33410 Telephone: Facsimile: 3 EFTA00223115 CERTIFICATE

es. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies o

DWARD MORSE and CAROL MORSE, Petitioners. Appeal from the United States District Court for the Southern District of Florida (Under Seal- Civ-Marra), Kenneth A. Marra, Judge. PETITIONERS' MOTION FOR EMERGENCY WRIT OF MANDAMUS Petitioners, EDWARD MORSE and CAROL MORSE, by and through their undersigned counsel, fi

This matter is pending before the Honorable United States District Court Judge, Kenneth Mires. 4. On March 25, 2009 and on April 23, 2009, Judge Marra entered detailed orders in this matter, copies of which are attached hereto and incorporated by reference herein. 5. _ As set forth in the Orders,

s petition for writ of certiorari with the attached letter to Respondent B.B. from the United States Attorney's Office. Dated: August 5, 2009 By: Diana L. Martin Florida Bar No. 624489 L,EOPOLD-KUVIN, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Telephone: 561-515-1400 Facsimile: 561-515-1

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

he reply is due 10 days from service of the last-filed response. Opposing counsel has contacted counsel for respondents (William J. Berger for ■.; Diana L. Martin for M.; and Deanna K. Shullman for the Post), who have all advised they have no objection to this motion. 2 EFTA00184013 I HEREBY CERTIFY that a

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

ORIDA JANE DOE, et al., Plaintiffs, I JUNE 12, 2009 vs. JEFFREY EPSTEIN, I Defendant. 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 16 For Jane Doe

w her to share the NPA with third parties (A-3). Judge Marra denied the motion, finding — as the U.S. Governm

reply is due 10 days from service of the last-filed response. Opposing counsel has contacted counsel for respondents (William J. Berger for E.W.; Diana L. Martin for B.B.; and Deanna K. Shullman for the Post), who have all advised they have no objection to this motion. 2 EFTA00233660 -Q-~.......4.11 0-4-9

ble to obtain the sealed nonprosecution agreement from the United States Attorney's Office pursuant to the terms of a federal order issued by Judge Marra of the Southern District of Florida: 09/12/2019 As Mr. Epstein's counsel stated at the June 25, 2009 hearing in front of Judge Colbath, B.B., as a

rsuant to the terms of a federal order issued by Judge Marra of the Southern District of Florida: 09/12/2019

or writ of certiorari with the attached letter to Respondent B.B. from the United States Attorney's Office. Dated: August 5, 2009 By: 09/12/2019 Diana L. Martin Florida Bar No. 624489 LEOPOLD-KUV1N, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Page CONF NT IAL Agency to Agency Requet: 19

United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr. Lee: I am writing to inquire a

ellee Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post. William J. Berger of Rothstein Rosenfeldt Adler, Fort Lauderdale, for appellee E.W. Diana L. Martin and Spencer T. Kuvin of Leopold-Kuvin, P.A., Palm Beach Gardens, for appellee B.B. EFTA00183082 Not final until disposition of timely filed motio

United States of America Case No.: 08-80736-CIV-MARRA/JOHNSON Dear Mr I am writing to inquire about w

ellee Palm Beach Newspapers, Inc., d/b/a The Palm Beach Post. William J. Berger of Rothstein Rosenfeldt Adler, Fort Lauderdale, for appellee E.W. Diana L. Martin and Spencer T. Kuvin of Leopold-Kuvin, P.A., Palm Beach Gardens, for appellee B.B. EFTA00233336 Not final until disposition of timely filed motio