DataSet-11
EFTA02728724
3 pg
…by and through Jane Doe's mother and natural guardian,
hereby move the Court for a Protective Order prohibiting Jeffrey Epstein and/or his counsel from
continuous and systematic harassment.
I HEREBY CERTIFY that a true and correct copy of…
DataSet-11
EFTA02728716
1 pg
…CF009454AXX
STATE OF FLORIDA,
VS.
JEFFREY EPSTEIN,
Defendant.
ORDER DIRECTING ATTORNEY FOR DEFENDANT TO RESPOND TO
"MOTION FOR PROTECTIVE ORDER"
THIS CAUSE came before the Court, in chambers, upon the submission
of a "Motion for Protective Order dated February 5…
DataSet-11
EFTA02728703
3 pg
…amounts to "continuous and systematic
harassment".
2. The Motion For Protective Order was filed by one of the attorneys purporting to
the
represent Jane Doe No. 1 in a separate civil proceeding.' While disagreein…
DataSet-11
EFTA02728757
2 pg
…MOTION FOR PROTECTIVE ORDER
COMES NOW, Witness Y. Doe, by and through undersigned counsel, upon the
representation of counsel for Defendant, Jeffrey Epstein, that he agrees to cancel the
deposition of Y. Doe, hereby withdraws her Motion for Protective Order.…
DataSet-11
EFTA02728897
3 pg
…by and through Jane Doe's mother and natural guardian,
hereby move the Court for a Protective Order prohibiting Jeffrey Epstein and/or his counsel from
continuous and systematic harassment.
I HEREBY CERTIFY that a true and correct copy of…
DataSet-11
EFTA02728718
3 pg
…by and through Jane Doe's
Jeffrey Epstein and/or his counsel from
hereby move the Court for a Protective Order prohibiting
continuous and systematic harassment.
foregoing was furnished by
…
DataSet-11
EFTA02728711
2 pg
…amounts to "continuous and systematic
harassment".
2. The Motion For Protective Order was filed by one of the attorneys purporting to
represent Jane Doe No. 1 in a separate civil proceeding.2 While disagreeing with the
Undersigned counsel for the…
DataSet-11
EFTA02728903
3 pg
…Jane Doe, by and through Jane Doe's mother and natural guardian,
hereby move the Court for a Protective Order prohibiting Jeffrey Epstein and/or his counsel from
continuous and systematic harassment.
!HEREBY CERTIFY that a true and correct copy…
DataSet-11
EFTA02728846
3 pg
…Florida v. Jeffrey Epstein
Please see attached Notice of Withdrawal of Motion for Protective Order.
THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY
CONTADISFORMATION THAT IS PRIVILEGED, CONFIDENTIAL…
DataSet-11
EFTA02728896
1 pg
…Jeffrey Epstein
Case No. 2006 CF 009454 A
Dear Judge McSorley:
Enclosed please find a copy of Jane Doe's Motion For Protective Order. The undersigned would
request ten (10) minutes of the Court's time in which to present…
DataSet-11
EFTA02728761
1 pg
…It is kindly requested that a fifteen
(15) minute or less special set hearing be scheduled on the enclosed Motion for Protective Order.
Please have your judicial assistant contact my office to schedule said hearing.
Thank you for your attention…
DataSet-11
EFTA02728710
1 pg
…Jeffrey Epstein
Case No. 2006CF009454A
Dear Judge McSorley:
Enclosed please find a courtesy copy of the Defendant's Response to the Motion for
Protective Order filed by Theodore Leopold.
lyfil ours,
Jack A. Goldberger
JAG/slm
Enclosure
cc: Lanna Belohlavek…
DataSet-11
EFTA02729469
13 pg
…written
orders do not support the petition and in fact undermine it.
The first federal order petitioner relies on is an "Order To Compel
Production And Protective Order" dated August 21, 2008. The second is an
"Order" dated February 12…
DataSet-11
EFTA02729329
15 pg
…s Office opposed disclosure noting its confidentiality provision, the
movant's right to access the agreement, and Judge Marra's protective order to which
the movants voiced no objection (A-4). On February 12, 2009,3 Judge Marra denied
the…
DataSet-11
EFTA02729494
26 pg
… that the agreement has a confidentiality provision, so
any production must be under a protective order (A-4:2); or wrote in a Declaration
that "the Agreement contained an express confidentiality provision." (PA-6:4).
And for good reason--the…
DataSet-11
EFTA02725185
2 pg
…as they could:
They forged the signature of judges, forged an Eleventh Circuit opinion, demanded
phony protective orders, sought discovery of Epstein's plane logs to find famous
people to extort, and they litigated claims under Jane Doe names to…
DataSet-11
EFTA02729370
8 pg
…possible federal indictment.
For this reason, your client is not covered by the Court's Protective Order and the
Agreement's confidentiality provision remains intact. If you arc unable to get a copy of the
Agreement via the civil discovery…
DataSet-11
EFTA02698630
4 pg
…obtaining, a protective
order preventing or limiting the disclosure and/or requiring that the Confidential
Information so disclosed be used only for the purposes for which the law or regulation
required, or for which the order was issued.
5. The…
DataSet-11
EFTA02729648
53 pg
…motion for protective order
on September 9, 2009 attempting to prohibit MrEps
tein's presence at the deposition. The
Defendant immediately filed a response (an Emerg
ency Motion) on Septem…
DataSet-11
EFTA02729351
19 pg
…Office opposed disclosure noting its confidentiality
provision, the movant's right to access the agreement, and Judge Marra's
protective order to which the movants voiced no objection (A-4). On
February 12, 2009,4 Judge Marra denied the motion…