EFTA00607365.pdf

Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER Now comes Intervenor, Jeffrey Epstein, who moves that this Honorable Court issue a supplemental Protective Order that would expand the limited Protective Order allowed in its decision Granting in Part and Denying in Part the Intervenors' Motion for a Protective Confidentiality Order. [D.E. 255 at 4]. The purpose of the proposed supplement to the previously ordered Protective Order is to require that any party would be required to file under seal any portion of the plea negotiation correspondence between the Government and Epstein's counsel, whether offered as an exhibit or quoted from in the content of a pleading or motion. Such a redacted filing would in all other respects be filed as a public filing unless subject to other orders of the Court, and each party would reserve the right to move to unseal any redacted pleading or sealed exhibit. After consultation with their counsel, both the Plaintiffs and the Government do not oppose the allowing of this Motion. EFTA00607365 Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 2 of 2 Respectfully submitted, JEFFREY EPSTEIN By His Attorneys, /s/Rov Black Roy Black Jackie Perczek BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 So. Biscayne Blvd., Suite 1300 Miami, Florida 33131 Tele: (305) 371-6421 Fax: (305) 358-2006 rblack@royblack.com jperczek@royblack.com /s/Martin G. Weinberg Martin G. Weinberg 20 Park Plaza, Suite 1000 Boston, Massachusetts 02116 Tele: (617) 227-3700 Fax: (617) 338-9538 owlmgw@att.net CERTIFICATE OF SERVICE I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this 8th day of October, 2014. /s/Roy Black Roy Black 2 EFTA00607366 Case 9:08-cv-80736-KAM Document 261-1 Entered on FLSD Docket 10/08/2014 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant PROPOSED ORDER OF CONFIDENTIALITY ("PROTECTIVE ORDER") THIS CAUSE came before the Court upon the Intervenor's Unopposed Motion for a Supplemental Protective Order. The Motion is hereby GRANTED, and it is ORDERED that: I. The Supplemental Protective Order applies to all correspondence between the United States Attorney's Office and the Intervenor and his counsel, including any attachments thereto, that was the subject of the Court's Order of June 18, 2013 [D.E. 188], hereinafter referred to as the "Confidential Discovery Material." 2. The Supplemental Protective Order incorporates the limited Protective Order of the Court's September 22, 2014 Order. [D.E. 255 at 4-5]. 3. The Parties and Intervenor are further ordered that the filing of any "Confidential Discovery Material" as defined in paragraph one of this Order I EFTA00607367 Case 9:08-cv-80736-KAM Document 261-1 Entered on FLSD Docket 10/08/2014 Page 2 of 2 shall be under seal, and further that any quotations from the "Confidential Discovery Material" in any pleading or motion shall be redacted from any public filing, with each party and the intervenor reserving the right to seek a further order unsealing the exhibit or the redacted portion of any filing. The Court also reserves the right to unseal any sealed exhibit or redacted portion of any filing with notice to the parties and intervenor. DONE and ORDERED in chambers in West Palm Beach Florida this 8th day of October, 2014. Kenneth Marra United States District Judge cc: All Counsel 2 EFTA00607368