EFTA00188544.pdf

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 )19-1444- 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: 2 to,emi/ea_ // EFTA00188546 WEST PALM BEACH OFFICF. 2139 PALM BEACH LAKES BLVD. WEST PALM BEACH. FLORIDA 33109 P.O. DRAWER 3626 WEST PALM BEACH. FLORIDA 33402 December 08, 2008 SEARCY DENNEY SCAROLA BARNHART ar—SHIPLEY. d ea? 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: Ow 1 AHASAFFoffrf.; TIC TOWLE HOUSE 117 NORTH CALHOUN STREET TALLAHASSEE. FL 32301-1231 P.O. DRAWER 1230 TALLAHASSEE. FLORIDA 32302 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 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 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. Dated cija0/0 r Signed b Printed Na 2 EFTA00188549 Case 9:08-cv-80736-KAM Document 26 Entered on FIST) Docket 08121/20O8 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. OS-80736-CTV-MARRAJJOHNSON RE: JANE DOES I AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore terms motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the • Sou them 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 beard. (c) Before counsel for petitioners show the Agreement to tbeir 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 EFTA00188550 .N Case 9:08-cv-B0736-KAM Document 26 Entered on FLSD Docket 08121/20O8 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 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 21.1 day of August, 2008 KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signinkbelow, 1 certify that I have reviewed and agree to be bound by the terms of this Order. Dated: q J a 51 OS) Signed by: Printed Name 2 EFTA00188551 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21120O8 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARItA/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 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 EFTA00188552 .N Case 9:08-0v-80736-KAM Document 26 Entered on FLSD Docket 08/21/20O8 Page 2 of 2 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 IYAttall 9 a e BSI en PALM BEACH LAKES OM. "EST RMM BEACH. FLORIDA 33409 n.0 DRAWER 3426 -fl'eST PALM BEACH. RORICA 33402 SEARCY DENNEY SCAROLA BARNHART F---SHIPLEYp.A —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: O16ILAW4Mttafela THE TOVA.E HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE. 'L 32331-1231 PD. DRAWER 1230 TKU.AHASSEF, FLORIDA 32302 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 • 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. / ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore renus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Sbuthem 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 arid 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 EFTA00188557 12/08/2008 16:13 FAX r (1005/007 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) MEE Signed by: 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 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. (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 of record 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