📄 Extracted Text (3,629 words)
PODHURST ORSECK
TRIAL & APPELLATE LAWYERS
CITY NATIONAL SANS BUILDING
SD WEST main
SUITE 600
MIAMI, FLORIDA 33130-1700
-3/ 3 //07
ean
O.Aft-r -1444-
)19
THE ENCLOSURE IS BEING SENT TO YOU WITHOUT A PERSONAL
LETTER SO THAT IT MAY REACH YOU EXPEDITIOUSLY.
EFTA00188544
case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a) The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c) Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d) If any individuals who have been identified by the USAO as victims of
EFTA00188545
Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21' day of August, 2008.
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and sae to be bound by the terms of this
Order.
Signed by:
Printed Name:
to,emi/ea_ //
2
EFTA00188546
SEARCY
DENNEY
WEST PALM BEACH OFFICF. SCAROLA Ow 1 AHASAFFoffrf.;
2139 PALM BEACH LAKES BLVD.
WEST PALM BEACH. FLORIDA 33109 BARNHART TIC TOWLE HOUSE
117 NORTH CALHOUN STREET
TALLAHASSEE. FL 32301-1231
P.O. DRAWER 3626
WEST PALM BEACH. FLORIDA 33402 ar—SHIPLEY. P.O. DRAWER 1230
TALLAHASSEE. FLORIDA 32302
d ea?
December 08, 2008
U.S. Department o us ice
500 South Australian Avenue, Suite 400
West Palm Beach, FL 33401
Re: Lpstein, et al
Epstein, et al
Dear Ms. Villafana:
Please find the enclosed Orders to Compel Production and Protective Orders
signed by my clients and myself regarding the above referenced matters.
Please fax me a copy of the settlement agreement between the United States
Attorney's Office for the Southern District of Florida and Jeffrey Epstein as
soon as possible.
If you should have any questions or concerns, please do not hesitate to
contact me.
a a -X -5S et:
WWW.SEARCYLAW.COM
EFTA00188547
Case 9:08-cv.-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 0B-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES l AND 2,
Petitioners.
ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
THIS CAUSE comes before the Court on the Petitioners' ore 'emu motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a) The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c) Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d) If any individuals who have been identified by the USAO as victims of
EFTA00188548
Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2
Epstein and/or any attomey(s) for those individuals requeit the opportunity to review the
those
Agreement, then the USAO shall produce the Agreement to those individuals, so long as
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acicnowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21m day of August, 2008.
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Datedcija0/0 r Signed b
Printed Na
2
EFTA00188549
Entered on FIST) Docket 08121/20O8 Page 1 of 2
Case 9:08-cv-80736-KAM Document 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
N
NO. OS-80736-CTV-MARRAJJOHNSO
RE: JANE DOES I AND 2,
Petitioners.
AND PROTECTIVE ORDER
ORDER TO COMPEL PRODUCTION
ing the
the Petitioners' ore terms motion seek
THIS CAUSE comes before the Court on
e for the
n of the Non -Pro secu tion Agre eme nt between the United States Attorney's Offic
productio
ideration of the
• ) and Jeffrey Epstein ("Epstein"). After cons
Sou them District of Florida ("USAO"
. . ED that the
the record, it is ORDERED AND ADJUDG
Motion, the arguments of the parties, and
tion Agreement,
The USAO shall produce the Non-Prosecu
Petitioners' Motion is GRANTED.
procedures:
ding any mod ifica tion s and adde nda thereto, in accordance with the following
inclu
Non-Prosecution Agreement,
(a) The USAO shall produce a copy of the
"Agreement"), to
thereto (collectively referred to as the
including any modifications and addenda
the attorneys for Petitioners.
disclose the Agreement or its terms
(b) Petitioners and their attorneys shall not
Epstein's
r, follo wing notice to and an opportunity for
to any third party absent further court orde
counsel to be beard.
ement to tbeir clients or discuss
(c) Before counsel for petitioners show the Agre
who must review
t provide a copy of this Order to petitioners,
the specific terms with them, they mus
nsel for
ement to abide by, the terms of the Order. Cou
and acknowledge their receipt of, and agre
O.
copy of that acknowledgment to the USA
petitioners must promptly provide a
d by the USAO as victims of
(d) If any individuals who have been identifie
EFTA00188550
Entered on FLSD Docket 08121/20O8 Page 2 of 2
Case 9:08-cv-B0736-KAM Document 26
.N
review the
those individuals request the opportunity to
Epstein and/or any attomey(s) for
those
the Agreement to those individuals, so long as
Agreement, then the USAO shall produce
to any third party
l not disclose the Agreement or its terms
individuals also agree that they shal
to be heard
e to and an opportunity for Epstein's counsel
absent further court order, following notic
any other individuals who have been
(e) Prior to producing the documents to
of Epstein and/or any attorneys) for those individuals, a copy
identified by the USAO as victims
to said individuals, who must review and acknowledge their receipt
of this Order must be provided
rs must promptly
terms of this Order. Counsel for petitione
of, and agreement to abide by, the
ent to the USAO.
provide a copy of that acknowledgm
Florida,
in West Palm Beach, Palm Beach County,
DONE and ORDERED in Chambers,
this 21.1 day of August, 2008
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
rd
Copies furnished to: all counsel of reco
s of this
reviewed and agree to be bound by the term
By signinkbelow, 1 certify that I have
Order.
J a 51 OS) Signed by:
Dated: q
Printed Name
2
EFTA00188551
Entered on FLSD Docket 08/21120O8 Page 1 of 2
Case 9:08-cv-80736-KAM Document 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80736-CIV-MARItA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
ECTIVE ORDER
ORDER TO COMPEL PRODUCTION AND PROT
ore ten us motion seeking the
THIS CAUSE comes before the Court on the Petitioners'
United States Attorney's Office for the
production of the Non-Prosecution Agreement between the
n ("Epstein"). After consideration of the
Southern District of Florida ("USAO") and Jeffrey Epstei
ORDERED AND ADJUDGED that the
Motion, the arguments of the parties, and the record, it is
produce the Non-Prosecution Agreement,
Petitioners' Motion is GRANTED. The USAO shall
with the following procedures:
including any modifications and addenda thereto, in accordance
tion Agreement,
(a) The USAO shall produce a copy of the Non-Prosecu
tively referred to as the "Agreement"), to
including any modifications and addenda thereto (collec
the attorneys for Petitioners.
ment or its terms
(b) Petitioners and their attorneys shall not disclose the Agree
ing notice to and an opportunity for Epstein's
to any third party absent further court order, follow
counsel to be heard.
s or discuss
(c) Before counsel for petitioners show the Agreement to their client
Order to petitioners, who must review
the specific terms with them, they must provide a copy of this
by, the terms of the Order. Counsel for
and acknowledge their receipt of, and agreement to abide
wledgment to the USAO.
petitioners must promptly provide a copy of that ackno
as victims of
(d) If any individuals who have been identified by the USAO
EFTA00188552
Case 9:08-0v-80736-KAM Document 26 Entered on FLSD Docket 08/21/20O8 Page 2 of 2
.N
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USA() shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USA() as victims of Epstein and/or any attorneys) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008:
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to: all counsel of record
B si nin bet w l certify that I have reviewed and a ee to be bound b the terms of this
Order.
Dated: lit/QS ) Signed b
Printed Na
2
EFTA00188553
12/08/2008 16:10 FAX Q001/007
SEARCY
DENNEY
IYAttall9a eBSI SCAROLA O16ILAW4Mttafela
en PALM BEACH LAKES OM.
"EST RMM BEACH. FLORIDA 33409 BARNHART THE TOVA.E HOUSE
517 NORTH CALHOUN STREET
TALLAHASSEE. 'L 32331-1231
n.0 DRAWER 3426
-fl'eST PALM BEACH. RORICA 33402 F---SHIPLEYp.A PD. DRAWER 1230
TKU.AHASSEF, FLORIDA 32302
—7100ko,
December 08, 2008
and U.S. Mail
500 South Australian Avenue, Suite 400
West Palm Beach, FL 33401
Re: Epstein, et al
I. Epstein, et al
Dear Ms. Villafana:
Please find the enclosed Orders to Compel Production and Protective Orders
signed by my clients and myself regarding the above referenced matters.
Please fax me a copy of the settlement agreement between the United States
Attorney's Office for the Southern District of Florida and Jeffrey Epstein as
soon as possible.
If you should have any questions or concerns, please do not hesitate to
contact me.
WWW.SEAfiCYLAW.COM
EFTA00188554
12/08/2008 16:11 FAX Q002/007
Case 9:08-cv.-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80736-CIV-MARRADOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
.1
ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
THIS CAUSE comes before the Court on the Petitioners' ore taws motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a) The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b) Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c) Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d) If any individuals who have been identified by the USAO as victims of
EFTA00188555
12/08/2008 16:12 FAX W11003/007
Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to' any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21' day of August, 2008.
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Da.eijao/o R/ Signed by:
Printed Nam
2
EFTA00188556
12/08/2008 16:12 FAX Z004/007
Entered on FLSD Docket 08/21/2008 Page 1 of 2
• Case 9:08-cv-80736-KAM Document 26
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80736-CIV-MARRADOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
/
PROTECTIVE ORDER
ORDER TO COMPEL PRODUCTION AND
ners' ore renus motion seeking the
THIS CAUSE comes before the Court on the Petitio
between the United States Attorn ey's Office for the
production of the Non-Prosecution Agreement
n ("Epstein"). After consideration of the
Sbuthem District of Florida ("USAO") and Jeffrey Epstei
it is ORDERED AND ADJUDGED that the
Motion, the arguments of the parties, and the record,
produce the Non-Prosecution Agreement,
Petitioners' Motion is GRANTED. The USAO shall
accordance with the following procedures:
including any modifications and addenda thereto, in
-Prosecution Agreement,
(a) The USAO shall produce a copy of the Non
(collectively referred to as the "Agreement"), to
including any modifications and addenda thereto
the attorneys for Petitioners.
Agreement or its terms
(b) Petitioners arid their attorneys shall not disclose the
notice to and an opportunity for Epstein's
to any third party absent further court order, following
counsel to be beard.
their clients or discuss
(c) Before counsel for petitioners show the Agreement to
of this Order to petitioners, who must review
the specific terms with them, they must provide a copy
abide by, the terms of the Order. Counsel for
and acknowledge their receipt of, and agreement to
acknowledgment to the USAO.
petitioners must promptly provide a copy of that
USAO as victims of
(d) If any individuals who have been identified by the
EFTA00188557
12/08/2008 16:13 FAX (1005/007
r
Case 9:08-cv-80736-KAM Document 2.6 Entered on FLSD Docket 08/21/20O8 Page 2 of 2
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent thither court order, following notice to and 3n opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USA() as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" clay of August, 2008:
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to; all counsel of record
By signinghelow, l certify that I have reviewed and avec to be bound by the terms of this
Order.
Dated: q a510 2) Signed by: MEE
Printed Name:
2
EFTA00188558
12/08/2008 16:14 FAX f~J006/007
• Case 9:08-cv-80736-KAM Document 26 Entered on FI.SD Docket 08/21/20O8 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER
THIS CAUSE comes before the Court on the Petitioners' ore tents motion seeking the
production of the Non-Prosecution Agreement between the United Slates Attorney's Office for the
Southern District ofFlorida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
, (a) The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(h) Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be beard.
(c) Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d) If any individuals who have been identified by the USAO as victims of
EFTA00188559
12/08/2008 16:15 FAX la 007/007
Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/20O8 Page 2 of 2
'
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e) Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Pulm Beach, Palm Beach County, Florida,
this 21" day of August, 2008:
KENNETH A. MARRA
UNITED STATES DISTRICT JUDGE
Copies furnished to: all counsel ofrecord
Disigning below, l certify that I have reviewed and agree tote bound by the tenns of this
Order.
Dated: 91f GOS, Signed by
Printed Name
2
EFTA00188560
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EFTA00188544
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