vision-fixhub/ds9-unparsed-05/077e58bcbfac66660e8a45ee2b23162bc7a8935d03bc4e231a071668eb726400.md

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