EFTA00213912.pdf

Case 9:08-cv-80893-KAM Document 214-1 Entered on FLSD Docket 09/02/2010 Page 1 of 5 Case 9:08-cv-80893-KAM Document 207 Entered on FLSD Docket 07/19/2010 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. Joint Stipulation Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their Joint Stipulation Regarding Certain Correspondence Obtained By Jane Doe's attorneys during discovery, and each state: I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel") received through discovery certain correspondence and documents (including content thereof) between Epstein's attomeys/agents and federal prosecutors (the "Correspondence"). 2. Counsel for Jane Doe and Counsel for Epstein disagree whether the Correspondence is confidential. 3. Without in any way altering the obligations set forth in the Addenda to Settlement Agreements entered into in the above-styled matter and in the matters of L,M. vs. Epstein, CASE NO. 502008 CA028051 JODOCMB AB and E.W. vs. Epstein, CASE NO. 502008 CA028058 XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v, Rothstein, CASE NO. 502009CA040800/OOOCMB AO and In Re: Jane Does 1 and 2, CASE 1 EXHIBIT EFTA00213912 Case 9:08-cv-80893-KAM Document 214-1 Entered on FLSD Docket 09/02/2010 Page 2 of 5 Case 9:08-cv-80893-KAM Document 207 Entered on FLSD Docket 07/19/2010 Page 2 of 3 NO. 08-80736-CIV-MARRA/JOHNSON. If Counsel (or Mr. Edwards as a Defendant in the Epstein v. Rothstein case) desires to file, use or disclose the Correspondence or contents thereof to anyone, Counsel agrees that prior to using any of the Correspondence in these proceedings or prior to providing or making the Correspondence available to anyone else, that they will provide seven (7) days notice to Epstein's counsel (Robert D. Critton, Jr. at [email protected] and Michael J. Pike at [email protected]) of their intent to use or provide the Correspondence or in the alternative, file the Correspondence under seal. If Epstein chooses to serve an objection based on a claim that the Correspondence should remain confidential, his objection must be served within seven (7) days from the date of the notice. If Epstein does serve an objection, Counsel (or Mr. Edwards as a defendant) will not file (unless filed under seal) nor disclose the Correspondence to the public or third parties until the court has ruled on the objection. However, Counsel (or Mr. Edwards as a defendant) may file the Correspondence under seal or provide the Correspondence to the court for an in camera inspection if any objection is made such that the court is in a position to rule on the objection. WHEREFORE, Plaintiff and Defendant requests that the Court enter an order on the above stipulation and grant any additional relief the Court deems just and proper. Local Rule 7.1 Statement Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and have agreed to same. Respectfully submitted, By: /s/ Robert D. Critton. Jr. ROBERT D. CRITFON, JR., ESQ. Florida Bar No. 224162 2 EFTA00213913 Case 9:08-cv-80893-KAM Document 214-1 Entered on FLSD Docket 09/02/2010 Page 3 of 5 Case 9:08-cv-80893-KAM Document 207 Entered on FLSD Docket 07/19/2010 Page 3 of 3 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CM/ECF on this 19th day of July, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Ave. Suite 1400 Suite #2 West Palm Beach, FL 33401-5012 Fort Lauderdale, FL 33301 561-659-8300 Phone: 954-524-2820 561-835-8691 Fax Fax: 954-524-2822 jinzegebellsouth.net Brad®oathtoiustice.com Co-Counselfor Defendant Jeffrey Epstein Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax cassellp®law.utah.edn Co-counselfor Plaintiff By: 1st Robert D, Critton. Jr. ROBERT D. CRITTON, JR, ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PUCE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 561/842-2820 Phone 561/243-0164 Fax (Co-Counselfor Defendant Jeffrey Epstein) 3 EFTA00213914 Case 9:08-cv-80893-KAM Document 214-1 Entered on FLSD Docket 09/02/2010 Page 4 of 5 Case 9:08-cv-80893-KAM Document 207-1 Entered on FLSD Docket 07/19/2010 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 — MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. Order Adopting and Entering Joint Stint*'teflon This matter came before the Court on Plaintiff; Jane Doe, and Defendant, Jeffrey Epstein's Joint Stipulation, and counsel being in agreement with the entry of the Stipulation, it is HEREBY ORDERED and ADJUDGED that 1. The Joint Stipulation is hereby Adopted and Entered. 2. Without in any way altering the obligations set forth in the Addenda to Settlement Agreements entered into in the above-styled matter and in the matters of L.M. vs. Epstein, CASE NO. 502008 CA028051 )OOCXMB AB and E.W. vs. Epstein CASE NO. 502008 CA028058 XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v. Rothstein, CASE NO. 502009CA040800XXXXMB AG and In Re: Jane Does 1 and 2, CASE NO. 08-80736-CIV-MARRA/JOHNSON. If Counsel (or Mr. Edwards as a Defendant in the Epstein v. Rothstein case) desires to file, use or disclose the Correspondence or contents thereof to anyone, Counsel agrees that prior to using any of the Conewondence in these proceedings or prior to providing or making the Correspondence available to anyone else, that they will provide seven (7) days notice to EFTA00213915 Case 9:08-cv-80893-KAM Document 214-1 Entered on FLSD Docket 09/02/2010 Page 5 of 5 Case 9:08-cv-80893-KAM Document 207-1 Entered on FLSD Docket 07/19/2010 Page 2 of 2 Epstein's counsel (Robert D. Critton, Jr. at rcrit@belclaw,cont and Michael J. Pike at [email protected]) of their intent to use or provide the Correspondence or in the alternative, file the Correspondence under seal. 3. If Epstein chooses to serve an objection based on a claim that the Correspondence should remain confidential, his objection must be served within seven (7) days from the date of the notice. If Epstein does serve an objection, Counsel (or Mr. Edwards as a defendant) will not file (unless filed under seal) nor disclose the Correspondence to the public or third parties until the court has ruled on the objection. However, Counsel (or Mr. Edwards as a defendant) may file the Correspondence under seal or provide the Correspondence to the court for an in camera inspection if any objection is made such that the court is in a position to rule on the objection. DONE and ORDERED this day of , 2010. Limns R. Johnson United States Magistrate Judge Courtesy Copies: Judge Kenneth Marra Counsel of Record EFTA00213916