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inst the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Compl. ¶¶ 19-20, L.M. • Epstein, Case No. 09- 81092-CIV-Cohn (S.D. Fla.) (asserting that plaintiff was "covered by" provisions of the Non-Prosec
y erroneous construction of 18 U.S.C. § 3858(b) — and where rescission "would [have] restore[d] the defendant to the approximate status quo ante"); Craig,. People, 986 P.2d 951, 959-60, 961-93 (Colo. 1999) (holding that plea agreement made no unlawful promises, but concluding that court would not have
inst the Defendant, Jeffrey Epstein, pursuant to [18 U.S.C. § 2255] and the [Non-Prosecution] agreement between the Defendant, Jeffrey Epstein, and the United States Government"); Compl. ¶¶ 19-20, L.M. • Epstein, Case No. 09- 81092-CIV-Cohn (S.D. Fla.) (asserting that plaintiff was "covered by" provisions of the Non-Prosec
y erroneous construction of 18 U.S.C. § 3858(b) — and where rescission "would [have] restore[d] the defendant to the approximate status quo ante"); Craig,. People, 986 P.2d 951, 959-60, 961-93 (Colo. 1999) (holding that plea agreement made no unlawful promises, but concluding that court would not have
June 11, 2009 motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9, Il. 16 -18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein had shown why the NPA ought to remain confidential and ordered the records unsealed.9 (A-16.) 9 It is important to note that the Stat
188 CONFIDENTIAL 09/12/2019 Agency to Agency Requet: 19-011 SDNY_GM_00331587 EFTA_002043 13 EFTA02729299 TABLE OF AUTHORITIES Federal Cases Craig v. Harney 331 U.S. 367 (1947) 8 Doe v. Hammond, 502 F. Supp. 2d 94 (D.D.C. 2007) 24 In re Grand Jury Investigation of Ven-Fuel, 441 F. Supp. 1
s June 11, 2009 motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9,11. 16 -18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein had shown why the NPA ought to remain confidential and ordered the records unsealed.9 (A-16.) It is important to note that the State
public event [and] [w]hat transpires in the court room is public property." Miami Herald Publ'g Co._'. Lewis, 426 So. 2d I, 7 (Fla. 1982) (quoting Craig'. Harney, 331 U.S. 367, 376 (1947)). When considering a request to seal judicial records, this Court's "analysis must begin 8 EFTA00183973 with
s June 11, 2009 motion (A-13). Epstein's counsel consented to that procedure. (A-18 at p. 9,11. 16 -18.) The Judge held that neither the State, nor the U.S. Government, nor Epstein had shown why the NPA ought to remain confidential and ordered the records unsealed.9 (A-16.) 9 It is important to note that the Stat
public event [and] [w]hat transpires in the court room is public property." Miami Herald Publ'g Co. I. Lewis, 426 So. 2d 1, 7 (Fla. 1982) (quoting Craig'. Harney, 331 U.S. 367, 376 (1947)). When considering a request to seal judicial records, this Court's "analysis must begin 8 EFTA00233620 with
Entities connected to both the United States Government and Craig Martin

Jeffrey Epstein
PERSON
Marc Rich
PERSON
Lesley Groff
PERSON
Richard Kahn
PERSON
United States
LOCATION
George W. Bush
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSONLeon Black
PERSON
Condoleezza Rice
PERSON
Alan Dershowitz
PERSON
Joe Biden
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Ghislaine Maxwell
PERSONDarren Indyke
PERSONJane Doe
PERSON
Paul Cassell
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION