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I AW
O PP IC E.
• Olaeleletwal4 •
AND ASSOCIATES
October 10, 2008
united states Attorney s uttice
500 South Australian Avenue
West Palm Beach, Florida 33401
Re:
Jane Does 1 and 2
Case Number: 08-80736-CIV-MARRA/JONSON
Dear
In accordance with the Order to Compel Production and Protective Order signed
by Judge Marra on August 21, 2008, I am providing to you herein copies of the Order
signed by those individuals who have seen and reviewed the Non-Prosecution Agreement
between the United States Attorney's Office and Jeffrey Epstein.
Esquire
nc osures
2028 HARRISON STREET,SUITE 202,
HOLLYWOOD, FLORIDA 33020
EFTA00177412
Case 9:08-cv-80736-KAM
ocument 26
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Page 1 of 2
NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES 1 AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00177413
Case 9:08-cv-80736-KAM
ocument 26
Entered on FLSD Dc
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Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(c)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008.
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated: Cir 8
Signed by:
Printed Name:
2
EFTA00177414
Case 9:08-cv-80736-KAM
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Page 1 of 2
NO. 08-80736-CIV-MARRA/JOIINSON
IN RE: JANE DOES 1 AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore ten us motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00177415
Case 9:08-cv-80736-KAM
ocument 26
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Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008.
z
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated:a
o
Signed by:
Printed Name
2
EFTA00177416
Aug.
. 200,8
9:30AM
No. 1962
P.
The Law Office of
DATE:
08/28/08
TO:
FAX NUMBER:
FROM:
Brad Edwards, Esquire
RE:
Jane Does 1 and 2/Epstein
OUR FILE NO.:
08-015
MESSAGE:
Signed Protective Order Attached.
Please forward the Agreement at this time.
We are transmitting
3
pages including this cover sheet.
PRODUCT
The information is intended only for the use of the individual or entity to whom It is
addressed. If you are not the intended recipient, you are hereby notified that any use, dissemination,
distribution or copying of this communication is strictly prohibited. If you have received this facsimile In
error, please immediately notify us by telephone and return the original message to us via U.S. mail.
2028 Harrison Street, Suite 202, Hollywood, Florida 33020
EFTA00177417
Aug. 28. 2008 9:30AM
No. 1962
P. 2
Case 9: 08-cv-80736-KAM
xument 26
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Page 1 of 2
NO. 08-80736-CV-MARRA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00177418
Aug. 28. 2098 9:30AM
No. 1962
P. 3
Case 9:08-cv-80736-KAM
ocument 26
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Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent flirter court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008.
/en
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated: g /F5 /of 3'
Signed by: e
M
Printed Nam
2
EFTA00177419
I AW OFFICE
• Oirtezeleekteas •
AND ASSOCIATES
October 29, 2008
UM=
blateS A UM ysv ce
500 South Australian Avenue
West Palm Beach, Florida. 33401
Re:
Jane Does 1 and 2
Case Number: 08-80736-CIV-MARRA/JONSON
Dear
In accordance with the Order to Compel Production and Protective Order signed
by Judge Marra on August 21, 2008, I am providing to you herein a copy of the Order
signed by another individual who has seen and reviewed the Non-Prosecution Agreement
between the United States Attorney's Office and Jeffrey Epstein.
Sincerely,
Esquire
2028 HARRISON STREET,SUITE 202, HOLLYWOOD, FLORIDA 33020
EFTA00177420
Case 9:08-cv-80736-KAM
ocument 26
Entered on FLSD Dr.
at 08/21/2008
Page 1 of 2
NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00177421
Case 9:08-cv-80736-KAM
ocument 26
Entered on FLSD Dc
at 08/21/2008
Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008.
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated: i
??,1Oit,
Signed by: _
Printed Name:
2
EFTA00177422