--- title: "DOJ Epstein Files, Data Set 9 (EFTA00204936)" source: "DOJ Epstein Files, Data Set 9" sourceUrl: "https://huggingface.co/datasets/ishumilin/epstein-files-ocr-complete" date: "2026-01-01" category: "DOJ Data Set" eftaNumber: "EFTA00204936" ocrPages: 0 ocrChars: 68827 ocrElapsed: 0.0 parseTier: "external" engine: "ishumilin OCR pipeline (engine undisclosed; CC0 mirror)" externalSource: "ishumilin-ocr-complete" externalLicense: "CC0-1.0" externalCredit: "ishumilin/epstein-files-ocr-complete (Hugging Face)" externalUrl: "https://huggingface.co/datasets/ishumilin/epstein-files-ocr-complete" --- Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, ) Case No. ) 08-80736-CIV-MARRA Petitioner, ) ) UNITED STATES OF AMERICA,) ) Respondent. ) West Palm Beach, Florida ) August 14, 2008 ___ TRANSCRIPT OF HEARING BEFORE THE HONORABLE KENNETH A. MARRA U.S. DISTRICT JUDGE Appearances: FOR THE PETITIONER Bradley J. Edwards, ESQ., and Paul G. Cassell, ESQ. FOR THE RESPONDENT Reporter (561)514-3768 Stephen W. Franklin, RMR, CRR, CPE Official Court Reporter 701 Clematis Street, Suite 417 West Palm Beach, Florida 33401 EFTA00204936 Page 2 (Call to the order of the Court.) THE COURT: Good afternoon. VOICES: Good afternoon, Your Honor. THE COURT: All right. This is the case of In Re: Jane Does 1 and 2, case number 08-80736-CIV-MARRA. May I have counsel state appearances, please, and if you can please try and speak up so we can hear you. MR. EDWARDS: Okay. Brad Edwards, on behalf of Jane Doe 1 and 2. MR. CASSELL: Paul Cassell, along with Mr. Edwards. THE COURT: Good afternoon. MR. LEE: Good afternoon, Your Honor. For the United States Government, Dexter Lee, Assistant U.S. Attorney, and Marie THE COURT: All right. Good afternoon. Mr. -- everyone, we're having trouble hearing you, so if you can try and speak up, and also if you could identify yourself before you begin speaking so the reporter can accurately indicate on the record who is speaking. I appreciate that. I scheduled this for a status conference in order to determine whether I'm going to need additional -- as far as the parties were concerned, whether either of the parties thought that I needed additional information in order to proceed with the pending motion by the Plaintiffs or whether EFTA00204937 Page 3 we have a complete record based upon what's already been submitted, and I wasn't quite sure where we were on that since we last met. So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position as far as where we stand on the record in terms of whether I need additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not need to be taken in the case for Your Honor to make a ruling. We have actually met with the U.S. Attorney, and we've had meaningful discussions in an attempt to resolve our issues. I think the only issue, we can probably agree to this right now, is that the victims are unable at this point in time to go any further with requesting a remedy from the Court without the full and complete plea agreement being produced to us from the U.S. Government, and the U.S. Government's hands are tied in that there's a confidentiality agreement within that plea agreement that prohibits them from turning that over. So at this point in time, we would be asking Your Honor to enter an order compelling them to turn over that EFTA00204938 Page 4 agreement, and at that point in time I think we can meet again and probably resolve our disputes amongst ourselves. again and probably resolve our disputes amongst ourselves. THE COURT: All right. So do I understand that you're modifying your claim for relief at this point and only seeking me to compel the Government to produce the plea agreement, or are you -- or is this a -- a preliminary step, after which you're then going to evaluate whether you want me to do something further? MR. EDWARDS: I think it's the latter, Your Honor. It is, and it will likely always be, our position that the victims' rights are violated. However, because of the legal consequences of invalidating the current agreement, it is likely not in my clients' best interest to ask for the relief that we initially asked for. So in order to effectively evaluate the situation and ask for the appropriate relief, we would just be asking Your Honor at this point in time to allow us to see the full entire plea agreement that is purportedly drafted to protect my victims. That only seems fair to know, you know, what the plea agreement says, especially in light of the fact that Mr. Epstein knows what the plea agreement says. THE COURT: All right. And then if I grant that relief, you will evaluate the agreement and then decide whether to either dismiss your case or go forward and ask for some additional relief? EFTA00204939 Page 5 MR. EDWARDS: That's correct, Your Honor. THE COURT: Is it your plan or is there any kind of -- been any kind of discussion between you and the Government as to what you -- if I grant the relief of requiring the Government to at least present you with the agreement and let you view it, has there been any discussion about you keeping it confidential and not letting it go any further than your clients and using it for your decision-making purposes, or do you wish to have it released to you, and you would be able to use it however you wished? MR. EDWARDS: Well, Your Honor, we would prefer that it be produced to us and not have to keep it confidential. I think that that creates an undue hardship on us. However, if it was Your Honor's order that we do maintain some confidentiality of the agreement, we would certainly abide by it. The reason we want it is not so that it's disseminated everywhere; however, there is a public interest in viewing what happens in the court process, and this is just part of it. There's no reason that it should be sealed or kept confidential. Seems to be an overwhelming reason to -- to make it public. However, that's not our intention. Our intention is just to view it, represent my clients and then evaluate it and ask the Court for the appropriate relief after we've seen it. EFTA00204940 Page 6 THE COURT: All right. And, again, although I hear you saying you think that it shouldn't be kept confidential because there's some public interest in it, but if you had it to use for whatever, to represent your client either in advising your clients whether to go forward with this case or not, or I guess to use it in connection with any other litigation that you might want to initiate on behalf of your clients where that agreement might have some relevance, what's the interest in using -- having the ability to disclose it beyond those purposes? MR. EDWARDS: Well, certainly if -- if the agreement was designed to protect these victims in a criminal as well as a civil context, and we are going to be filing civil cases against Mr. Epstein, and this agreement, undoubtedly it will play a big role in the amount of protection the victims have been allotted, as well as the course of action in the civil cases. It seems inevitable that it's going to become, you know, more public at that point in time, and I think that's in the very near future. At this point in time, it's not intention to make it public, but I think that inevitably happens as soon as civil litigation begins, and this is at the heart of it, so . . . THE COURT: Well, civil litigation has already begun, hasn't it? EFTA00204941 Page 7 THE COURT: Okay. All right. MR. EDWARDS: At least for some other parties, with other attorneys and other things, so . . . THE COURT: Well, you filed a case yesterday, didn't you? MR. EDWARDS: We filed one of them. It is not on behalf of one of the Jane Does that I'm representing in this action. THE COURT: Okay. All right. MR. EDWARDS: Just so that we're clear. THE COURT: I haven't seen the name, so I didn't know who it was on behalf of. All right. Let me hear from Mr. Lee or ## Ms. I understand that you're under a confidentiality agreement, and I understand that you feel restricted in what you can unilaterally do, but I've already entered some rulings in this case that have made portions of that agreement public. Is there any reason to keep the rest of the agreement confidential, other than you're obligated by the agreement and don't want to be in a position where you've unilaterally violated it absent a court order? MR. LEE: Yes, Your Honor. This is Dexter Lee. Good afternoon. EFTA00204942 Page 8 Your Honor, we do feel bound by the confidentiality provision such that we could not voluntarily disclose this non-prosecution agreement without court order compelling us to do so. The provision in the non-prosecution agreement required us to notify Mr. Epstein and his attorneys of any attempts to have this document disclosed in a public forum, and we have done so. They have expressed their desire that if this document is to be disclosed to the Petitioners in this case, that it be done pursuant to a protective order which would preclude the victims from disseminating it publicly. We believe that is appropriate in this action. It would allow them access to the document, which they claim they have a need to have, and that's fine. They can review it and determine where they wish to go. We believe there's no public interest in having this disseminated. Now, should there be subsequent litigation between Mr. Edwards' clients and Mr. Epstein, and the subject matter of this agreement should arise, then Mr. Epstein and Mr. Edwards will be in a position to litigate that in whatever forum it is, rather than having that issue disposed of where they're not present to voice their objections. So we would ask the Court to, if it compels us to disclose it, to do so under a protective order which would EFTA00204943 Page 9 EFTA00204944 Page 10 THE COURT: Okay. But they're not parties to the agreement. THE COURT: Okay. Other than the fact that the Government bound itself in the agreement not to disclose it, and you require a court order to have it disclosed, what would be the public interest, or what would be the justification for denying disclosure of the agreement at least to purported victims of Mr. Epstein's conduct? Why shouldn't the victims who the Government, as I understand it, provided notice of their rights under the Act that they had the status of victims, why shouldn't they have the opportunity to see that agreement? MS. : Your Honor, I guess I will respond. I was prepared to -- I need to highlight an issue for the Court. I was prepared to argue today that we had provided the victims with the portion of the agreement that is relevant to them. Last night and this morning, in conversations with Mr. Epstein's attorneys, they have said for the first time that they do not believe that one portion of the agreement is binding, and that is the portion that has been disclosed to the victims. So I can no longer say that they have the portion that is relevant to them. THE COURT: I'm sorry, I didn't quite follow that, EFTA00204945 Page 11 You've had discussions with Mr. Epstein's counsel as to what? MS. : Your Honor, in preparation for today's hearing, I was -- I had been working to confirm with Mr. Epstein's attorney that the agreement that I have described in my declaration is the one that they are performing under. Last night and this morning for the first time, I was told that they believe that a portion of the agreement that is described in my declaration and that was disclosed to the victims does not bind them. So as of this point, the victims have not received at least what Mr. Epstein claims is the portion relevant to them. THE COURT: Okay. Your understanding is that Mr. Epstein's taking the position that the portions of the agreement that have already been disclosed are not -- is not binding on Mr. Epstein? MR. LEE: Your Honor, this is Dexter Lee. If I may? The agreement initially negotiated was executed in September of 2007. That's part one, I will call it. In October, there was an addendum to the executed agreement which occurred the month before. There was some more discussions, and there was a letter that was submitted EFTA00204946 Page 12 to Mr. Epstein's attorneys by the United States Attorney in December. That's part three, I will call it. There is now a dispute between the Government and Mr. Epstein's attorneys about whether certain portions after the original agreement are effective and binding. I just need to make the Court aware of that and also Mr. Edwards and Judge Cassell. MR. EDWARDS: This is the first time -- This is Brad Edwards speaking. This is the first time we're hearing any of this. This is obviously even further evidence that the victims were unaware of the plea agreement that was being worked out. But, nonetheless, I don't think that it changes our position, in that we believe we're entitled to not only the plea agreement, but all of the addenda that have been attached to that plea agreement and have become part of that plea agreement, just so that what we're asking for is clear. MR. LEE: Your Honor, this is Dexter Lee. We are prepared to give all three hopefully, in our view, pursuant to a protective order preventing public disclosure, but we just want the Court and the Petitioners' counsel to know that there is a dispute ongoing right now about which portions are effective and which are not. And we can discuss that with them at the conclusion of the hearing. THE COURT: All right. But again, as far as my EFTA00204947 Page 13 earlier question, even though there's a dispute now apparently between Mr. Epstein and the Government as to what portions of the agreement are or are not binding, does the Government have any reason why the victims should not have the benefit of seeing these -- the agreement, whether, you know, it's going to be held binding down the road or not, other than you agreed in a confidentiality order not to disclose it? But beyond that, is there any justification that the Government can provide to me as to why the victims, people who have been identified by the Government as victims of Mr. Epstein, should not have the benefit of seeing this plea agreement, or non-prosecution agreement, whatever you want to term it? MR. LEE: Your Honor, this is Dexter Lee. When you refer to victims, do you mean victims beyond the three that are parties to the instant litigation? THE COURT: I mean -- yes, I'm talking about anyone who the Government may have disclosed as a -- as a -- or sent notice to based upon your understanding of who might have been a potential or an alleged victim of Mr. Epstein's conduct, whether they're part of this lawsuit or not. MR. LEE: Well, if the Court is asking whether we could expand the protective order such that it would permit disclosure to those other victims identified that have received notification already, I believe that would be EFTA00204948 Page 14 THE COURT: Okay. But I guess my real question is do you have any reason that you could advance why they should not get it? Let's just limit ourselves to the victims who are the Jane Does in this case before we go beyond that. Is there any reason that the Government can advance why the two Jane Does 1 and 2 in this case should not have the opportunity to view the plea agreement, or the deferral agreement or the addenda to it? Can anyone justify not letting them see it? MR. LEE: Your Honor, this is Dexter Lee. No, we cannot. THE COURT: Okay. All right. Now, Mr. Edwards. MR. EDWARDS: Yes. THE COURT: Is there any reason why I shouldn't, assuming I'm going to allow or require the Government to produce the agreement and the addenda to your clients in this case -- and we'll talk about other victims in a minute -- is there any reason why, at least initially, it shouldn't be subject to a protective order so that in the case, for example, that you filed yesterday on behalf of an alleged victim under a Jane Doe, where you specifically reference this agreement in your -- in one the counts, that it shouldn't remain subject to a protective order at least until EFTA00204949 Page 15 Mr. Epstein has the opportunity to litigate whether or not it should be disclosed beyond -- beyond your clients or other victims? MR. EDWARDS: At this point, Your Honor, I think that would probably be fair. My only real concern is that if there's an order out there where anybody can access on PACER and it says, "okay, at this point I'm ordering the Government to disclose this plea agreement," I just want to make sure if anybody else feels entitled to that agreement, whether it's other victims, or counsel, or what have you, that they be required to request it from the Government or these attorneys rather than try to subpoena or request it from my office, knowing that I have access to this confidential agreement. Other than that, no, I don't have any other reasons why that's not a reasonable order. THE COURT: All right. And let's assume I think it should be available to any person that the Government has identified as an alleged victim of Mr. Epstein's conduct, and they've sent notice of their rights under the statute as a victim to this -- these individuals, and I permit disclose to your clients, or anyone else who fits into the category of victim as described by the Government, and require -- you know, again, impose a protective order that it shouldn't go to anyone beyond that until such time as, in a pending EFTA00204950 Page 16 lawsuit, I conclude that the protective order should be lifted after Mr. Epstein has an opportunity to be heard on that issue, is there anything else that you would need at this point? MR. EDWARDS: No, Your Honor. This is Brad Edwards. At this point in time that's all we're requesting. THE COURT: And Mr. Lee or Ms. **, if I conclude that anyone that you've identified as a victim and notified as a victim of their rights with respect to the investigation of Mr. Epstein is entitled to view the agreements, subject to a protective order until such other time that I say it should be released beyond that, do you -- is there any reason why I shouldn't make it available to all of the people who have been identified by you as a victim? MR. LEE: This is Dexter Lee, Your Honor. The answer is no, there's no problem, with the exception of the grand jury issue that my colleague, Ms. **, mentioned earlier. I may have to defer to her right now on that issue to see if that would preclude what the Court is asking. THE COURT: All right. Hold on one second. (Brief pause in proceedings.) THE COURT: Mr. Edwards, is there any reason why you would need to see the names of others that the Government ```markdown EFTA00204951 ``` Page 17 may have been investigating that might appear -- whose names might appear in these agreements? Is there any interest that you would have in that or need to see that information? MR. EDWARDS: Well, the primary interest would be that those are obviously important witnesses for any case that my clients have against Mr. Epstein, witnesses that Mr. Epstein is clearly aware of, since he has access to the complete full agreement, and it seems inherently unfair that he would have access to the names -- to a witness list that my clients would not be privy to. THE COURT: Well, why wouldn't you be able to get those through discovery in the civil litigation? MR. EDWARDS: And that may be an appropriate time to get it. But that would be my primary objection for not getting the names of the victims, whether now or eventually. THE COURT: No, as I understand it, this is not the names of other victims, this is the names of other individuals that the Government may have been investigating in connection with their investigation of Mr. Epstein, and they're concerned about grand jury secrecy and information that may have been brought before the grand jury that should not be made public at this point, as I understood the Government's position. ```markdown Is that correct, Ms. ? MS. : Yes, Your Honor. ``` EFTA00204952 Page 18 MR. EDWARDS: Well, Your Honor, as I understand this -- and correct me if I'm wrong, anybody -- this non-prosecution agreement provides for a dismissal or immunity for other individuals, and I think these are the individuals that we are talking about. But all of that is inextricably intertwined within this agreement, and it is this agreement in its total form that is supposed to protect the victims. I think that the victims have a right to know of these other individuals, who my clients were also familiar with during the course of this conduct, and how it protects them in this case. And I don't see why they should, once again, get an incomplete version of this. Because these are characters that are very intertwined with the -- the -- with Mr. Epstein's conduct. This is not completely and wholly indifferent or irrelevant conduct for some other people. This is all part of the same conduct, and I think that's probably necessary for us to evaluate the effect of this agreement and whether or not we're going to continue to pursue this case. THE COURT: All right. So you're assuming that the agreement also provides that the Government will not prosecute these other individuals? That's what your assumption is? MR. EDWARDS: Yes, Your Honor. THE COURT: Do you have any information to -- upon EFTA00204953 Page 19 which you make that conclusion, or is that just an assumption? MR. EDWARDS: That is all just, you know, the discussions that we've had with various individuals, law enforcement, clients, things like that. And putting it together, that's what we believe is a portion of this agreement. If I'm wrong about that, one of the U.S. Attorneys on the phone can probably correct me. But that's my belief. THE COURT: All right. Well, assume they're just mentioned in the agreement in some way. And I'm not sure how or why they would be mentioned. But assume they're mentioned in the agreement, but there's no agreement by the Government not to prosecute them. Is there any reason for you to have their names if it's other than for the purpose of finding out the extent to which the Government has agreed not to prosecute Mr. Epstein and other individuals? MR. EDWARDS: That's a tough question for me to answer without knowing in what context those individuals are listed. However, I just renew my previous argument that I do believe they're intertwined, and I think that, once again, if we get a version of this plea agreement without the portions that pertain to these other individuals, then we could possibly be in the same position where we are not sure as to the full extent of the protection allowed under this EFTA00204954 Page 20 agreement. That would be -- without knowing how they're mentioned, I can't voice any other objection to not getting those portions but I could certainly foresee where, you know, we're not going to get out of it what we're asking. THE COURT: All right. Well, again, I didn't understand the Government to want to redact the entire provisions that relate to these individuals. I understood that they just wanted to redact their names. Am I correct, Ms. ? MS. : Yes. THE COURT: Okay. So if you were given the agreement with these names redacted but you saw the context in which they were listed, and then, after seeing the agreement and the context in which their names were mentioned, if it presented a problem to you that they were being withheld, couldn't you then just, you know, file another motion for disclosure of the names after you've had an opportunity to, you know, evaluate whether or not there's any real need for you to get these names? MR. EDWARDS: Okay. We could do that at that time, Your Honor. THE COURT: All right. Anything else that anybody wants to add to what -- our discussion? MR. EDWARDS: One more thing, Your Honor. This is Brad Edwards. EFTA00204955 Page 21 Same topic. My clients are currently in a position where they may be speaking to local law enforcement regarding certain issues pertaining to this case, and if we are unable to have access to the other named people in this agreement, it may put them at a disadvantage in terms of whether or not it would be in their benefit to speak with other law enforcement about this case. I mean, certainly if there's individuals who have been given immunity in this agreement, then it would only be to the disadvantage of my clients to continue to try to pursue criminal charges. So in that regard, that would be my only objection to not having the names of these other individuals. THE COURT: All right. Well, again, you're assuming that there's some kind of immunity or deferral of prosecution -- MR. EDWARDS: That's correct. THE COURT: -- given to people other than Mr. Epstein, correct? MR. EDWARDS: That's correct. THE COURT: Okay. And that's something that would be clear once you got the agreement and you read it, and if the names were -- you know, if that was apparent in the agreement, then you could come back and ask me to require the disclosure of the names. MR. EDWARDS: Okay. That sounds fair. EFTA00204956 Page 22 EFTA00204957 Page 23 THE COURT: Again, Mr. Edwards, do you have any problem with that procedure, you know, you're permitted to disclose -- the names of these individuals who are also getting the benefit of a non-prosecution agreement would be disclosed to you under the terms of the protective order without prejudice to you being able to, in any litigation that ensues, seeking to disclose it beyond the limited group? MR. EDWARDS: No, Your Honor, that's fine. THE COURT: All right. Well, then I'm going to order the Government to produce the agreement and any addenda to Mr. Epstein -- Mr. Edwards in this case, and it would be available also to any other individuals who have been identified by the United States as victims in connection with the investigation of Mr. Epstein, subject to a protective order. Which, I'm going to ask the parties to try and work on the language of a protective order to submit to me that would prohibit disclosure to anyone other than Mr. -- to the victim, or victims' counsel, without prejudice to the victims seeking the ability to disclose it beyond that limited group after Mr. Epstein has an opportunity to be heard on further disclosure. MR. EDWARDS: Okay. Thank you, Your Honor. MR. LEE: This is Dexter Lee. Very well, Your Honor. We appreciate your time. THE COURT: All right. So is there any questions EFTA00204958 Page 24 about it? Is there anything unclear about what I'm ordering? And I'm also -- okay. And the names of the -- there will be no redaction in the agreements, but any victim has to -- who gets notice of this has to agree to be bound by the protective order until further order of the Court. MS. : Your Honor, this is Marie Just to be clear, we are not under an obligation to advise the victims of this, but if the victim asks for a copy of the document, this is the procedure that we'll follow? THE COURT: Well, I'm not going to tell you whether you have any obligation under the Act to disclose this or not. I don't want to get into that. I don't know that you do, but I don't want to say that you don't. So if you have an independent obligation to disclose this to victims under the Act, then -- then I'm not telling you not to do it. MS. [ ]: Okay. But your order isn't ordering us to do it. We will have to make our evaluation. THE COURT: I'm only ordering it to be available to victims, and the -- and then you have to decide whether you're obligated under the Act to disclose it to anyone else who falls into that category. MS. [ ]: Okay. Thank you, Your Honor. THE COURT: All right. Thank you. EFTA00204959 Page 25 THE COURT: Have a good day. (Proceedings concluded.) ## CERTIFICATE I, Stephen W. Franklin, Registered Merit Reporter, and Certified Realtime Reporter, certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled matter. Dated this 20th day of AUGUST, 2008. Stephen W. Franklin, RMR, CRR EFTA00204960 Page 26 ## A
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confidential (6)5:7,13,21 6:2 7:21 15:14
confidentiality (5)3:22 5:15 7:16 8:1 13:7
confirm (1)11:5
connection (3)6:6 17:19 23:13
consequences (1)4:12
contain (1)22:4
contains (1)9:11
context (4)6:13 19:19 20:12,14
continue (2)18:18 21:10
conversations (1)10:19
copy (1)24:9
correct (10)5:1 17:24 18:2 19:8 20:9 21:16,18,19 22:12 25:7
counsel (5)2:6 11:2 12:22 15:11 23:18
counts (1)14:24
course (2)6:17 18:10
court (68)1:1,19 2:1,2,4,11,15 3:19 4:3,22 5:2,19 5:24 6:1,24 7:2,5,10,12,23 8:3,24 9:2,7,16 10:1 10:4,6,16,25 11:14 12:6,21,25 13:17,22 14:2 14:14,16 15:17 16:8,21,22,24 17:11,16 18:20 18:25 19:10 20:5,11,22 21:13,17,20 22:1,4,8 22:13,21 23:1,9,25 24:5,11,19,24 25:1
co-counsel (1)22:19
CPE (1)1:19
creates (1)5:13
criminal (2)6:12 21:10
CRR (2)1:19 25:11
current (1)4:12
currently (3)9:6,12 21:1
## D
TermNumber
Dated (1)25:9
day (2)25:1,9
December (1)12:2
decide (2)4:23 24:20
decision (1)22:7
decision-making (1)5:9
declaration (2)11:7,10
defer (1)16:19
deferral (2)14:9 21:14
denying (1)10:8
described (3)11:7,10 15:23
designed (1)6:12
desire (1)8:8
determine (2)2:22 8:16
Dexter (9)1:17 2:13 7:24 11:19 12:18 13:14 14:12 16:16 23:23
disadvantage (2)21:5,9
disclose (14)6:10 8:2,25 10:5 13:8 15:8,21 22:22 23:3,7,19 24:12,15,21
disclosed (9)8:7,9 10:6,22 11:11,16 13:18 15:2 23:5
disclosing (1)22:18
disclosure (8)10:8 12:21 13:24 20:17 21:24 22:16 23:17,21
discovery (1)17:12
discuss (1)12:24
discussion (3)5:3,6 20:23
discussions (4)3:15 11:2,25 19:4
dismiss (1)4:24
dismissal (1)18:3
disposed (1)8:22
dispute (3)12:3,22 13:1
disputes (1)4:2
disseminated (2)5:18 8:17
disseminating (1)8:11
dissemination (1)9:1
```markdown DISTRICT (3) 1:1,1,12 document (4) 8:7,9,14 24:10 Doe (3) 1:3,2,9 14:23 drafted (1) 4:18 ``` ## E
earlier (2)13:116:19
Edwards (44)1:152:8,8,103:4,9,104:95:1,11
6:117:1,3,7,118:19,2112:6,8,914:14,1515:4
16:5,6,2417:4,1318:1,2419:3,1820:20,24,2521:16,19,25
21:16,19,2522:6,1823:1,8,11,22
effect (1)18:17
effective (2)12:5,23
effectively (1)4:15
either (3)2:234:246:4
enforcement (3)19:521:2,7
ensues (1)23:7
enter (1)3:25
entered (2)7:189:21
entire (2)4:1820:6
entitled (3)12:1415:1016:11
Epstein (23)4:216:148:6,19,209:2111:13,17
13:2,1115:116:2,1117:6,7,1919:1721:18
22:11,2323:1114,20
Epstein's (10)10:9,2011:2,6,1512:1,413:20
especially (1)4:20
ESQ (2)1:15,15
et (1)9:15
evaluate (6)4:7,15,235:2418:1720:18
evaluation (1)24:18
eventually (1)17:15
evidence (3)3:7,1312:11
example (1)14:22
exception (1)16:18
executed (2)11:21,23
expand (1)13:23
expressed (1)8:8
extent (2)19:16,25
## F
Fact (2)4:20 10:4
facts (1)3:6
fair (3)4:19 15:5 21:25
falls (1)24:22
familiar (1)18:9
far (3)2:22 3:5 12:25
feel (2)7:17 8:1
feels (1)15:10
file (1)20:16
filled (3)7:5,7 14:22
filling (1)6:13
finding (1)19:15
fine (2)8:15 23:8
first (5)3:5 10:20 11:8 12:8,10
flits (1)15:22
Florida (3)1:1,7,20
follow (2)10:25 24:10
foregoing (1)25:6
foresee (1)20:3
form (1)18:7
forum (2)8:7,22
forward (2)4:24 6:5
Franklin (3)1:19 25:5,11
full (4)3:19 4:17 17:8 19:25
further (6)3:18 4:8 5:8 12:11 23:20 24:5
future (1)6:19
## G
getting (3)17:1520:223:4
give (1)12:19
given (3)20:1121:8,17
go (7)3:184:245:7 6:5 8:16 14:6 15:24
going (12)2:223:74:7 6:13,18 13:6 14:17 18:18 20:4 23:9,15 24:11
good (7)2:2,3,11,12,157:25 25:1
Government (27)2:133:214:5 5:4,5 10:5,10 12:3 13:2,4,9,10,18 14:7,17 15:8,12,18,23 16:25 17:18 18:21 19:13,16 20:6 22:10 23:10
Government's (3)3:219:2017:23
grand (3)16:1817:20,21
grant (2)4:225:4
group (3)22:2323:7,19
guess (5)6:610:1414:2 22:3,15
guilty (2)9:12,22
## H
verbnumber
hands (1)3:21
happens (2)5:19 6:21
hardship (1)5:13
hear (4)2:7 3:4 6:1 7:14
heard (3)16:2 22:24 23:20
hearing (6)1:10 2:16 9:8 11:5 12:10,24
heart (1)6:22
held (1)13:6
Highlight (I)10:15
Hold (I)16:22
Honor (35)2:3,12 3:10,14,25 4:9,17 5:1,11 7:24
8:1 9:3,10 10:14 11:4,19 12:18 13:14 14:12
15:4 16:5,16 17:25 18:1,24 20:21,24 22:3,15
23:8,22,24 24:6,23,25
HONORABLE (I)1:11
Honor's (I)5:14
hopefully (I)12:19
hurdle (I)22:6
## 1
Identified6)13:10,2415:1916:9,1523:13
identify(1)2:18
immunity(3)18:421:8,14
important(1)17:5
impose(1)15:24
incomplete(1)18:12
independent(1)24:15
indicate(1)2:19
indicted(1)9:23
indifferent(1)18:15
individuals(21)9:5,11,17,18,2315:2117:1818:4
18:5,9,2219:4,17,19,2320:721:8,12 22:10
23:3,12
inevitable(1)6:17
inevitably(1)6:21
inextricably(1)18:6
information(4)2:2417:3,2018:25
inherently(1)17:8
initially(3)4:1411:2114:20
initiate(1)6:7
instant(1)13:16
intention(3)5:22,236:20
interest(9)4:135:186:3,98:17 9:24 10:7 17:2,4
intertwined(3)18:6,1319:21
invalidating(1)4:12
investigating(2)17:1,18
investigation(4)9:2016:1117:1923:14
irrelevant(1)18:15
issue(8)3:168:229:1410:15 16:3,18,20 22:5
issues(2)3:1621:3
## J | | | | :--- | :--- | | **J** (1) | 1:15 | | **Jane** (7) | 1:3 2:5,9 7:8 14:6,8,23 | | **Judge** (2) | 1:12 12:7 | | **jump** (1) | 22:6 | | **jury** (3) | 16:18 17:20,21 | | **justification** (2) | 10:8 13:8 | | **justify** (1) | 14:10 | ## K
NumberFormula
keep (2)5:127:20
keeping (1)5:7
KENNETH (1)1:11
kept (2)5:216:2
kind (3)5:2321:14
know (19)4:19,196:18 7:13 9:23 12:22 13:6
15:2418:8 19:3 20:3,16,18 21:22 22:5,14,17
23:224:13
knowing (3)15:1319:19 20:1
known (1)9:20
knows (1)4:21
## L ## ```markdown language (3) 22:4,9 23:16 ```
NumberFormula
law (3)19:421:2,6
lawsuit (2)13:2116:1
Lee (22)1:172:12,13 7:14,24,24 9:4 11:19,19
12:18,18 13:14,14,22 14:12,12 16:8,16,16 22:1
23:23,23
legal (1)4:11
letter (1)11:25
letting (2)5:714:11
let's (2)14:515:17
lifted (1)16:2
light (1)4:20
limit (1)14:522:18
limited (3)22:2323:7,19
list (1)17:9
listed (2)19:2020:13
litigate (2)8:2115:1
litigation (7)6:7,22,248:18 13:16 17:12 23:6
local (1)21:2
longer (1)10:23
## M
EnglishSpanish
malintain (1)5:15
Marie (4)1:17 2:14 9:3 24:6
MARRA (1)1:11
matter (2)8:19 25:8
mean (3)13:15,17 21:7
meaningful (1)3:15
meet (1)4:1
mentioned (6)16:19 19:11,12,12 20:2,15
EFTA00204961 Page 27
VerbNumber
Merit (1)25:5
met (2)3:3;14
minute (1)14:19
modifying (1)4:4
month (1)11:24
morning (2)10:19 11:8
motion (2)2:25 20:17
## N
name (1)7:12
named (1)21:4
names (20)9:5,11,17 16:25 17:1,9,15,17,17 19:15 20:8,12,14,17,19 21:12,22,24 23:3 24:2
near (1)6:19
necessarily (1)9:20
necessary (1)18:17
need (11)2:22 3:6,13 8:15 10:15 12:6 16:3,25 17:3 20:19 22:17
needed (1)2:24
negotiated (1)11:21
night (2)10:19 11:8
non-prosecution (5)8:3,5 13:12 18:3 23:4
notice (4)10:11 13:19 15:20 24:4
notification (1)13:25
notified (1)16:10
notify (1)8:6
number (1)2:5
## 0
Object1)22:20
objection(3)17:14 20:2 21:11
objections(1)8:23
obligate(1)22:9
obligated(2)7:21 24:21
obligation(3)24:8,12,15
obligations(1)9:13
obviously(2)12:11 17:5
occurred(1)11:24
October(1)11:23
office(1)15:13
Official(1)1:19
okny(18)2:8 7:2,10 9:16 10:1,4 11:14 14:2,14
15:8 20:11,20 21:20,25 23:22 24:2,17,23
once(3)18:11 19:21 21:21
ongoing(1)12:22
opportunity(7)10:13 14:9 15:1 16:2 20:18 22:24
23:20
order(32)2:1,21,24 3:25 4:15 5:14 7:23 8:3,10,25
9:6 10:6 12:20 13:7,23 14:21,25 15:6,16,24
16:1,12 22:17,18,18 23:5,10,15,16 24:5,5,17
ordering(4)15:8 24:1,18,19
ore(1)22:18
original(1)12:5
overwhelming(1)5:21
## P
PACER (1)15:7
Palm (2)1:7,20
part (6)5:20 11:22 12:2,16 13:21 18:16
parties (6)2:23,23 7:3 10:1 13:16 23:15
Paul (2)1:15 2:10
pause (1)16:23
pending (2)2:25 15:25
people (6)13:10 16:15 18:15 21:4,17 22:14
performing (1)11:8
permit (2)13:23 15:21
permitted (1)23:2
person (1)15:18
pertain (1)19:23
pertaining (1)21:3
Petitioner (2)1:4,15
Petitioners (2)8:9 12:21
phone (1)19:8
Plaintiffs (2)2:25 3:5
plan (1)5:2
play (1)6:15
plea (15)3:20,22 4:5,18,20,21 9:22 12:12,15,16
12:17 13:12 14:9 15:9 19:22
please (2)2:6,7
pled (1)9:12
point (13)3:18,24 4:1,4,17 6:19,20 11:12 15:4,8
16:4,7 17:22
portion (7)10:17,21,22,24 11:9,13 19:6
portions (7)7:19 11:15 12:4,23 13:3 19:22 20:3
position (9)3:5 4:10 7:22 8:21 11:15 12:14 17:23
19:24 21:1
possibly (1)19:24
potential (1)13:20
preclude (2)8:11 16:20
prefer (1)5:11
prejudice (2)23:6,18
preliminary (1)4:6
preparation (1)11:4
prepared (3)10:15,16 12:19
present (2)5:5 8:23
presented (1)20:15
press (1)9:15
EnglishSpanish
preventing (1)12:20
previous (1)19:20
primary (2)17:4,14
privacy (1)9:24
privy (1)17:10
probably (5)3:17 4:2 15:5 18:17 19:8
problem (3)16:17 20:15 23:2
procedure (2)23:2 24:10
proceed (1)2:25
proceedings (3)16:23 25:2,7
process (1)5:19
produce (3)4:5 14:18 23:10
produced (2)3:20 5:12
prohibit (1)23:17
prohibits (1)3:23
prosecute (4)18:22 19:14,17 22:10
prosecution (1)21:15
protect (3)4:18 6:12 18:7
protection (2)6:16 19:25
protective (15)8:10,25 12:20 13:23 14:21,25
15:24 16:1,12 22:16,17 23:5,14,16 24:5
protects (1)18:10
provide (2)9:1 13:9
provided (2)10:11,17
provides (2)18:3,21
provision (2)8:2,5
provisions (1)20:7
public (15)5:18,22 6:3,18,21 7:20 8:7,17 9:1,10:9:21,22 10:7 12:20 17:22
publicly (1)8:12
purported (1)10:9
purportedly (1)4:18
purpose (1)19:15
purposes (2)5:9 6:10
pursuant (2)8:10 12:20
pursue (2)18:19 21:10
put (1)21:5
putting (1)19:5
question (3)13:114:219:18
questions (1)23:25
quite (2)3:210:25
## Q ## R
NumberName
read (1)21:21read (1)
real (3)14:2 15:6 20:19real (3)
really (1)22:16really (1)
Realtime (1)25:6reason (12)
reason (12)5:17,20,21 7:20 13:4 14:3,7,16,20 16:14,24 19:14reasonable (1)
reasonable (1)15:16reasonals (1)
reasons (1)15:15received (2)
received (2)11:12 13:25record (5)
record (5)2:19 3:1,6,11 25:7redact (2)
redact (2)20:6,8redacted (1)
redaction (1)20:12redaction (1)
refer (1)13:15refer (1)
reference (1)14:23reference (1)
regard (1)21:11regarding (1)
regarding (1)21:2Registered (1)
registered (1)25:5relate (1)
relate (1)20:7related (1)
relates (1)22:16released (2)
released (2)5:9 16:13relevance (1)
relevance (1)6:8relevant (3)
relevant (3)10:18,24 11:13relief (7)
relief (7)4:4,13,16,23,25 5:4,24rely (1)
rely (1)3:8remain (1)
remain (1)14:25remedy (1)
renew (1)3:19renew (1)
renew (1)19:20reporter (5)
reporter (5)1:19,19 2:18 25:5,6represent (2)
represent (2)5:23 6:4representing (1)
representing (1)7:8request (2)
request (2)15:12,13requesting (2)
requesting (2)3:19 16:7require (4)
require (4)10:6 14:17 15:23 21:23required (2)
required (2)8:6 15:11requiring (1)
requiring (1)5:5resolve (2)
resolve (2)3:16 4:2respect (1)
respect (1)16:10respond (1)
respond (1)10:14Respondent (2)
Respondent (2)1:7,17rest (1)
rest (1)7:20restricted (1)
restricted (1)7:17review (1)
review (1)8:15right (31)
right (31)2:4,15 3:17 4:3,22 6:1 7:1,2,10,14 9:2 12:22,25 14:14 15:17 16:20,22 18:8,20 19:10 20:5,22 21:13 22:1,8,13,21,25 23:9,25 24:24rights (4)
rights (4)4:11 10:11 15:20 16:10RMR (2)
RMR (2)1:19 25:11road (1)
road (1)13:6role (1)
role (1)6:15Rule (1)
Rule (1)9:13ruling (1)
## ```markdown rulings (I) 7:19 ``` ## S
NumberName
saw (1)20:12Saw
saying (2)6:2 9:4Saying
says (3)4:20,21 15:7Says
scheduled (1)2:21Scheduled
sealed (1)5:20Sealed
second (1)16:22Second
secrecy (1)17:20Secrecy
see (7)4:17 10:13 14:11 16:20,25 17:3 18:11Seeing
seeing (3)13:5,11 20:13Seeking
seeing (3)4:5 23:7,19Seen
seen (2)5:25 7:12Sense
sense (1)9:21Sent
sent (2)13:18 15:20September
September (1)11:22Situation
situation (1)4:15Soon
soon (1)6:21Sorry
Sorry (3)9:9,16 10:25Sounds
Sounds (1)21:25SOUTHERN
SOUTHERN (1)1:1Speak
speak (3)2:7,17 21:6Speaking
specifically (1)14:23Specifically
stand (1)3:5Stand
state (1)2:6State
States (5)1:1,6 2:13 12:1 23:13Status
status (2)2:21 10:12Statute
statute (1)15:20Step
step (1)4:6Stephen
Stephen (3)1:19 25:5,11Stipulation
stipulation (1)3:7Street
Street (1)1:20subject
subject (7)8:19 9:19,19 14:21,25 16:12 23:14submit
submit (1)23:16submitted
submitted (3)3:2,7 11:25subpoena
subpoena (1)15:13subsequent
subsequent (1)8:18sufficient
sufficient (1)3:11Suite
Suite (1)1:20supposed
supposed (1)18:7Sure
Sure (5)3:2,9 15:9 19:11,24
## T
NumberEnglish
taken (1)3:13taken (1)
talk (1)14:19talk (1)
talking (2)13:17 18:5talking (2)
tell (2)22:4 24:11tell (2)
telling (2)22:8 24:16telling (2)
tenus (1)22:18tenus (1)
term (1)13:13term (1)
terms (3)3:6 21:5 23:5terms (3)
Thank (4)23:22 24:23,24,25Thank (4)
thing (1)20:24thing (1)
things (2)7:4 19:5things (2)
think (19)3:12,12,16 4:1,9 5:13 6:2,19,21 9:13,24think (19)
12:13 15:4,17 18:4,8,16 19:21 22:20
thought (1)2:24thought (1)
three (3)12:2,19 13:15three (3)
tied (1)3:21tied (1)
time (17)3:18,24 4:1,17 6:19,20 10:20 11:9 12:8time (17)
12:10 15:25 16:7,13 17:13 20:20 22:23 23:24
today (1)10:16today (1)
today's (1)11:5today's (1)
told (1)11:9told (1)
topic (1)21:1topic (1)
total (1)18:7total (1)
tough (1)19:18tough (1)
transcript (2)1:10 25:7transcript (2)
trouble (2)2:16 9:7trouble (2)
true (1)22:13true (1)
try (5)2:7,17 15:13 21:10 23:15try (5)
turn (1)3:25turn (1)
turning (1)3:23turning (1)
two (1)14:7two (1)
## U
CodeFormula
unable(2)3:18 21:3
unaware(1)12:12
unclear(1)24:1
understand(7)4:3 7:16,17 10:10 17:16 18:1 20:6
understanding(2)11:14 13:19
understood(2)17:22 20:7
undoubtedly(1)6:15
undue(1)5:13
unfair(1)17:8
unilaterally(2)7:18,23
United(5)1:1,6 2:13 12:1 23:13
use(3)5:10 6:4,6
U.S(6)1:12 2:13 3:15,20,21 19:7
## ```markdown (1) 1:5 ``` ## ```markdown ``` | | | | :--- | :--- | | various (1) | 19:4 | | version (2) | 18:12 19:22 |
victim (11)13:2014:2315:1921,2316:910,15
23:1824:3,9
victims (35)3:174:11,196:1216:811:109,10,12
10:1723:1111:1212:1113:4,910,15,15,24
14:5,1915:3,1117:1517:1818:8,822:14 23:13
23:1818:249,15,20
view (5)5:6,2312:2014:916:11
viewing (1)5:19
(28)1:172:147:159:3,3,7,9,1810:3,14
11:1,4,1816:8,1917:24,2520:9,1022:1,3,12
22:15,2524:6,7,17,23
violated (2)4:117:23
voice (2)8:2320:2
VOICES (2)2:324:25
voluntarily (1)8:2
## ```markdown w ```
W(3)1:1925:5,11
want(12)4:75:17 6:7 7:22 12:21 13:13 15:9 20:6
    22:5,624:13,14
wanted(2)20:822:2
wants(1)20:23
wasn't(1)3:2
way(1)19:11
West(2)1:7,20
we'll(2)14:1924:10
we're(10)2:163:12 7:11 12:10,14,17 16:7 18:18
    20:4,4
we've(3)3:155:25 19:4
wholly(1)18:14
wish(2)5:98:16
wished(1)5:10
withheld(1)20:16
witness(1)17:9
witnesses(2)17:5,6
work(1)23:15
worked(1)12:12
working(1)11:5
wouldn't(1)17:11
written(1)22:17
wrong(2)18:219:7
## yesterday (2) 7:5 14:22 ## ```markdown 0 ``` ```markdown 08-80736-CIV-MARRA (2) 1:3 2:5 ``` ```markdown 1 **(3)** 2:5,9 14:8 14 **(1)** 1:7 ```
2 (3)2:5,914:8
20th (1)215:9
2007 (1)411:22
2008 (2)11:725:9
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