EFTA00177412.pdf

I AW O PP IC E. • Olaeleletwal4 • AND ASSOCIATES October 10, 2008 united states Attorney s uttice 500 South Australian Avenue West Palm Beach, Florida 33401 Re: Jane Does 1 and 2 Case Number: 08-80736-CIV-MARRA/JONSON Dear In accordance with the Order to Compel Production and Protective Order signed by Judge Marra on August 21, 2008, I am providing to you herein copies of the Order signed by those individuals who have seen and reviewed the Non-Prosecution Agreement between the United States Attorney's Office and Jeffrey Epstein. Esquire nc osures 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 EFTA00177412 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dc at 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 1 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 EFTA00177413 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dc at 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 (c) 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 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. Dated: Cir 8 Signed by: Printed Name: 2 EFTA00177414 Case 9:08-cv-80736-KAM xument 26 Entered on FLSD Dc at 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOIINSON IN RE: JANE DOES 1 AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore ten us 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 EFTA00177415 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dc at 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. z 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. Dated:a o Signed by: Printed Name 2 EFTA00177416 Aug. . 200,8 9:30AM No. 1962 P. The Law Office of BRAD EDWARDS & ASSOCIATES, LLC FACSIMILE COVER SHEET DATE: 08/28/08 TO: FAX NUMBER: FROM: Brad Edwards, Esquire RE: Jane Does 1 and 2/Epstein OUR FILE NO.: 08-015 MESSAGE: Signed Protective Order Attached. Please forward the Agreement at this time. We are transmitting 3 pages including this cover sheet. THE INFORMATION CONTAINED IN THIS TRANSMISSION IS CONFIDENTIAL AND MAY ALSO BE SUBJECT TO ATTORNEY-CLIENT PRIVILEGE OR MAY CONSTITUTE PRIVILEGED WORK PRODUCT The information is intended only for the use of the individual or entity to whom It is addressed. If you are not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited. If you have received this facsimile In error, please immediately notify us by telephone and return the original message to us via U.S. mail. 2028 Harrison Street, Suite 202, Hollywood, Florida 33020 EFTA00177417 Aug. 28. 2008 9:30AM No. 1962 P. 2 Case 9: 08-cv-80736-KAM xument 26 Entered on FLSD Dc. at 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CV-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 EFTA00177418 Aug. 28. 2098 9:30AM No. 1962 P. 3 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dc at 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 flirter 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. /en 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. Dated: g /F5 /of 3' Signed by: e M Printed Nam 2 EFTA00177419 I AW OFFICE • Oirtezeleekteas • AND ASSOCIATES October 29, 2008 UM= blateS A UM ysv ce 500 South Australian Avenue West Palm Beach, Florida. 33401 Re: Jane Does 1 and 2 Case Number: 08-80736-CIV-MARRA/JONSON Dear In accordance with the Order to Compel Production and Protective Order signed by Judge Marra on August 21, 2008, I am providing to you herein a copy of the Order signed by another individual who has seen and reviewed the Non-Prosecution Agreement between the United States Attorney's Office and Jeffrey Epstein. Sincerely, Esquire 2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020 EFTA00177420 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dr. at 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 EFTA00177421 Case 9:08-cv-80736-KAM ocument 26 Entered on FLSD Dc at 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 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" 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. Dated: i ??,1Oit, Signed by: _ Printed Name: 2 EFTA00177422