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PODHURST ORSECK TRIAL & APPELLATE LAWYERS CITY NATIONAL BANK BUILDING 25 WEST FLAGLER STREET SUITE 800 MIAMI, FLORIDA 33130-1780 3/31/09 Plane sue allent? Ouder to Compel Pesticis fem That you THE ENCLOSURE IS BEING SENT TO YOU WITHOUT A PERSONAL LETTER SO THAT IT MAY REACH YOU EXPEDITIOUSLY.
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. If any individuals who have been identified by the USAO as victims of
Epstein and/or any attorneys) 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. Dent. 3/206/09 Signed by: Quandra Fall Printed Name: alexantRa/Tall 2
•WEST PALM BEACH OFFICE: WEST PALM BEACH, FLORIDA 33402 SEARCY. DENNEY SCAROLA BARNHART &SHIPLEY.A Hillarmens •TALLAHASSEE OFFICE: THE TOWLE HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE, FL 32301-1231 O. DRAWER 123 ALLAHASSEE. FLORIDA 3230 December 08, 2008 U.S. Department of Justice 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Re: Epstein, 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. Sincerely WWW.SEARCYLAW.COM
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: 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. 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. If any individuals who have been identified by the USAO as victims of
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 agrecment 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. Dace 9 / 20/08 Signed by Printed Nam 2
Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008
SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRAJJOHNSON 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 Souther 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 "A greement"), 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 receipl of, and agreemerit to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. If any individuals who have been identified by the USAO as victims of
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 Palrn 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, 1 certify that I have reviewed and agree to be bound by the terms of this Order. Dated: 9/23/08 Signed by: Printed Name: 2
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. If any individuals who have been identified by the USAO as victims of
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. Dated: 916/08 Signed by Printed Nam 2
12/08/2008 16:10 FAX #001/007 E$ WEST PALM BEACH OFFICE: L DRAWER 38 IST PALM BEACH. FLORIDA 334 SEARCY DENNEY ( SCAROLA BARNHART 8-SHIPLEYeA Blaine (од) •TALLAHASSEE OFFICE: THE TOWLE HOUSE TALIASE, 1L.1231-25 PO. DRAWER 1230 ALLAHASSEE, FLORIDA 32302 December 08, 2008 and U.S. Mail O.o, Depanmentor dustice 500 South Australian Avenue, Suite 400 West Palm Beach, FL. 33401 Re: • Epstein, 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. WWW.SEARCYLAW.COM
12/08/2008 16:11 FAX #002/007 Case 9:08-Cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of2 • 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 morifications 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. Before counsel for petitioners show the Agrcement 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. If any individuals who have been identified by the USAO as victims of
12/08/2008 16:12 FAX 2003/007 Entered on FLSD Docket 08/21/2008
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 reccipt 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 21ª day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furished to: all counsel of record Bysiening below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dad. 9/20/08 Signed by: Printed Name 2
12/08/2008 16:12 FAX @004/007 Case 9:08-Cv-80736-KAM Document 26 SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/IOHNSON IN RE: JANE DOES 1 AND2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the i production of the Non-Prosecution Agreement between the United Stales 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 "A greement"), 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 their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must revicw and acknowledge their receipt of, and agreemerit to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgrent lo the USAO. If any individuals who have been identified by the USAO as victims of
12/08/2008 16:13 FAX @005/007 • 5 Case 9:08-cy-80736-KAM Document 26 Epstein and/or any altorney(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 discloso 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 procucing 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 ofthis Order must be provided to said individuals, who must review and acknowledge their recsip! 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: kin KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, 1 certify that I have reviewed and agree to be bound by the terms of this Order: Dated: 9/23/08 Signed by: ( Printed Name: y
12/08/2008 16:14 FAX : @006/007 Case 9:08-CV-8073G-KAM Document 26 Entered on FI.SD Docket 08/21/2008 Page 1012 SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CTV-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' are 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 atlorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terns 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 pelitioners, 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. If any individuals who have been identified by the USAO as victims of
12/08/2008 16:15 FAX 4007/007 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 torms 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, Palin Beach County, Florida, this 21" day of Augusi, 2008: KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies fumished to: all counsel of record Order. By signing below, I cetify that 1 have revieved and agree to be bound by the terms of this Dated: 916/08 Signed by! Printed Name 2