DataSet-9
EFTA00072622
3 pg
…due to technical problems. I am forwarding it on to you myself. Please confirm receipt.
Thanks,
Chris
Counsel:
Attached please find our proposed Protective Order, with a redline and a clean copy.
As a prefatory note, it is equally in…
DataSet-9
EFTA01206074
12 pg
…could prove their "allegation of a
deliberate conspiracy between Epstein andfederal prosecutors...." Id. (emphasis added).
In their motion for a protective order, the Intervenors have requested that before the
Court allows the Plaintiffs to publicly use the details of the…
DataSet-9
EFTA01145383
2 pg
…DONE AND ORDERED thi ay of January, 2013 est Palm Beach,
Palm Beach County, Florida.
DAVID F.
CIRCUIT COU JUDGE
Copy furnished:
See attached list.
…
DataSet-9
EFTA01176822
12 pg
…re:
ROTHSTEIN ROSENFELDT ADLER, P.A., Case No. 09-3479 I -BKC-RBR
Chapter 11
Debtor.
STIPULATED PROTECTIVE ORDER BY AND BETWEEN
TRUSTEE AND JEFFREY EPSTEIN
Plaintiff, Herbert Stettin,…
DataSet-9
EFTA00583385
4 pg
…v.
UNITED STATES OF AMERICA, :
Defendant.
EPSTEIN'S REPLY IN SUPPORT OF SUPPLEMENTAL PROTECTIVE ORDER
There is no doubt that the Eleventh Circuit has held that Epstein's plea negotiation and
settlement communications are not privileged. We acknowledged this throughout…
DataSet-9
EFTA01093428
2 pg
…hereby
CONSIDERED, ORDERED AND ADJUDGED that this Court's Order of
January 29, 2013 on Counter-Defendant's Motion for Protective Order is modified as
follows:
I. The Counter-Defendant shall respond to the discovery within twenty (20)
days of…
DataSet-9
EFTA00209235
1 pg
…Date: Fri, 16 May 2014 20:35:38 +0000
Importance: Normal
Attachments: Victim-Response-Mtn-Protective-Order_FILED_UNDER_SEAL_5.16.14.pdf; M_Seal_-
Victim-Response-Mtn-Protective-Order_5.16.14_-_Stamped.PDF
Inline-Images: image001.png;…
DataSet-9
EFTA00605487
2 pg
…DONE AND ORDERED thi ay of January, 2013 est Palm Beach,
Palm Beach County, Florida.
DAVID F.
CIRCUIT COU JUDGE
Copy furnished:
See attached list.
…
DataSet-9
EFTA00605751
13 pg
…counsel), and the Plaintiffs' suggestion that they could make the CDM
available to the public in the future (just not "at this point"), the requested protective order
is more than justified. As Chief Judge Bowdre likewise concluded in a similar…
DataSet-9
EFTA00605701
9 pg
…to in paragraphs 5.a.iii through 5.a.v above who is
furnished a copy ofany CDM shall first be given a copy of this Protective Order and required
to read it and be bound by its terms.
9…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…police reports, counsel for Ms. Giuffre immediately informed counsel for
Defendant that she would like those documents to be treated as confidential under the Court’s
Protective Order (DE 62).
Significantly, two of the police reports identify Ms. Giuffre as…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND
TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM
DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335)
…
DataSet-9
EFTA00070830
7 pg
…United States Attorney has served a grand jury subpoena on the Law Firm for
documents that are covered by the Protective Order.' The Government has represented that the
subpoena was validly issued as part of an ongoing investigation into Jeffrey…
DataSet-9
EFTA00157723
3 pg
…CODE, SECTION 3509(d) AND FLORIDA LAW,
THE ATTACHED DOCUMENT IS TO BE TREATED AS
CONFIDENTIAL AND SHALL NOT BE DISCLOSED
EXCEPT IN CONNECTION WITH A LEGAL
PROCEEDING.
3505-022
…
DataSet-9
EFTA00723160
14 pg
…S Willem J. Berger for the Plaintiff,. and
POCCIII913056 strain Tint
leasibleASLa DONALD name 9 we're hero on our client's motion for protective order.
…
DataSet-9
EFTA00299859
5 pg
…Correspondence
-Attorney's Notes
-Deposition Subpoena to JE
-Pleadings
-Affidavit of Richard Barnett
-Mi's Motion for A Protective Order Barring Direct or Indirect Contact by Epstein
-Mi's Motion for Preservation of Evidence Relating to Correspondence with the US…
DataSet-9
EFTA00299864
6 pg
…EPSTEIN
-CORRESPONDENCE
-ATTORNEY'S NOTES
-DEPOSITION SUBPOENA TO JE
-PLEADINGS
-AFFIDAVIT OF RICHARD BARNETT
MOTION FOR A PROTECTIVE ORDER BARRING DIRECT OR INDIRECT CONTACT BY EPSTEIN
MOTION FOR PRESERVATION OF EVIDENCE RELATING TO CORRESPONDENCE WITH THE US
ATTORNEYS OFFICE
-SUPPLEMENTAL…
DataSet-9
EFTA01005843
2 pg
…other matters relating to Mr. E stein. So,
ou were no doubt aware of her intent to require confidentiality and seek a protective order regarding
deposition well before Ms. McCawley sent us that last minute email. In that email she…
DataSet-9
EFTA01246415
4 pg
…SECTION 3509(d) AND FLORIDA LAW,
THE ATTACHED DOCUMENT IS TO BE TREATED AS
CONFIDENTIAL AND SHALL NOT BE DISCLOSED
EXCEPT IN CONNECTION WITH A LEGAL
PROCEEDING.
3501.112-014
…
DataSet-9
EFTA01248790
1 pg
…number is and her cell number is
. Bogota considers this lead covered. Set Lead 1: (Info) ALL
RECEIVING OFFICES Read and clear.
••
(Overall Document Classification Required)
…