Text extracted via OCR from the original document. May contain errors from the scanning process.
PODHURST ORSECK
SD WEST main
SUITE 600
MIAMI, FLORIDA 33130-1700
-3/ 3//07
ean
O.Aft-r
)19-1444-
EFTA00188544
case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 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
EFTA00188545
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21' day of August, 2008.
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and sae to be bound by the terms of this
Order.
Signed by:
Printed Name:
2
to,emi/ea_
//
EFTA00188546
2139 PALM BEACH LAKES BLVD.
WEST PALM BEACH. FLORIDA 33109
P.O. DRAWER 3626
WEST PALM BEACH. FLORIDA 33402
December 08, 2008
SEARCY
DENNEY
SCAROLA
BARNHART
ar—SHIPLEY.
d
ea?
U.S. Department o us ice
500 South Australian Avenue, Suite 400
West Palm Beach, FL 33401
Re:
Lpstein, et al
Epstein, et al
Dear Ms. Villafana:
Ow 1 AHASAFFoffrf.;
TIC TOWLE HOUSE
117 NORTH CALHOUN STREET
TALLAHASSEE. FL 32301-1231
P.O. DRAWER 1230
TALLAHASSEE. FLORIDA 32302
Please find the enclosed Orders to Compel Production and Protective Orders
signed by my clients and myself regarding the above referenced matters.
Please fax me a copy of the settlement agreement between the United States
Attorney's Office for the Southern District of Florida and Jeffrey Epstein as
soon as possible.
If you should have any questions or concerns, please do not hesitate to
contact me.
a
a
-X
-5S et:
EFTA00188547
Case 9:08-cv.-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 1 of 2
NO. 0B-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES l AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore 'emu motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00188548
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 2 of 2
Epstein and/or any attomey(s) for those individuals requeit the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acicnowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21m day of August, 2008.
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated cija0/0 r
Signed b
Printed Na
2
EFTA00188549
Case 9:08-cv-80736-KAM
Document 26
Entered on FIST) Docket 08121/20O8
Page 1 of 2
NO. OS-80736-CTV-MARRAJJOHNSON
RE: JANE DOES I AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore terms motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
•
Sou them District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
. .
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be beard.
(c)
Before counsel for petitioners show the Agreement to tbeir clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00188550
.N
Case 9:08-cv-B0736-KAM
Document 26
Entered on FLSD Docket 08121/20O8
Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorneys) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21.1 day of August, 2008
Copies furnished to: all counsel of record
By signinkbelow, 1 certify that I have reviewed and agree to be bound by the terms of this
Order.
Dated: q J a 51 OS)
Signed by:
Printed Name
2
EFTA00188551
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21120O8
Page 1 of 2
NO. 08-80736-CIV-MARItA/JOHNSON
IN RE: JANE DOES I 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
EFTA00188552
.N
Case 9:08-0v-80736-KAM
Document 26
Entered on FLSD Docket 08/21/20O8
Page 2 of 2
Epstein and/or any attomey(s) for those individuals request the opportunity to review the
Agreement, then the USA() shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USA() as victims of Epstein and/or any attorneys) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" day of August, 2008:
Copies furnished to: all counsel of record
B si nin bet w l certify that I have reviewed and a ee to be bound b the terms of this
Order.
Dated: lit/QS )
Signed b
Printed Na
2
EFTA00188553
12/08/2008 16:10 FAX
Q001/007
IYAttall 9 a
e BSI
en PALM BEACH LAKES OM.
"EST RMM BEACH. FLORIDA 33409
n.0 DRAWER 3426
-fl'eST PALM BEACH. RORICA 33402
SEARCY
DENNEY
SCAROLA
BARNHART
F---SHIPLEYp.A
—7100ko,
December 08, 2008
and U.S. Mail
500 South Australian Avenue, Suite 400
West Palm Beach, FL 33401
Re:
Epstein, et al
I. Epstein, et al
Dear Ms. Villafana:
O16ILAW4Mttafela
517 NORTH CALHOUN STREET
TALLAHASSEE. 'L 32331-1231
PD. DRAWER 1230
TKU.AHASSEF, FLORIDA 32302
Please find the enclosed Orders to Compel Production and Protective Orders
signed by my clients and myself regarding the above referenced matters.
Please fax me a copy of the settlement agreement between the United States
Attorney's Office for the Southern District of Florida and Jeffrey Epstein as
soon as possible.
If you should have any questions or concerns, please do not hesitate to
contact me.
WWW.SEAfiCYLAW.COM
EFTA00188554
12/08/2008 16:11 FAX
Q002/007
Case 9:08-cv.-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 1 of 2
NO. 08-80736-CIV-MARRADOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
.1
THIS CAUSE comes before the Court on the Petitioners' ore taws motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be heard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00188555
12/08/2008 16:12 FAX
W11003/007
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 2 of 2
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to' any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21' day of August, 2008.
Copies furnished to: all counsel of record
By signing below, I certify that I have reviewed and agree to be bound by the terms of this
Order.
Da. eijao/o R/
Signed by:
Printed Nam
2
EFTA00188556
12/08/2008 16:12 FAX
Z004/007
•
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21/2008
Page 1 of 2
NO. 08-80736-CIV-MARRADOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
/
THIS CAUSE comes before the Court on the Petitioners' ore renus motion seeking the
production of the Non-Prosecution Agreement between the United States Attorney's Office for the
Sbuthem District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(b)
Petitioners arid their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be beard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00188557
12/08/2008 16:13 FAX
r
(1005/007
Case 9:08-cv-80736-KAM
Document 2.6
Entered on FLSD Docket 08/21/20O8
Page 2 of 2
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent thither court order, following notice to and 3n opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USA() as victims of Epstein and/or any attomey(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida,
this 21" clay of August, 2008:
Copies furnished to; all counsel of record
By signinghelow, l certify that I have reviewed and avec to be bound by the terms of this
Order.
Dated: q
a510 2)
MEE
Signed by:
Printed Name:
2
EFTA00188558
12/08/2008 16:14 FAX
f~J006/007
•
Case 9:08-cv-80736-KAM
Document 26
Entered on FI.SD Docket 08/21/20O8
Page 1 of 2
NO. 08-80736-CIV-MARRA/JOHNSON
IN RE: JANE DOES I AND 2,
Petitioners.
THIS CAUSE comes before the Court on the Petitioners' ore tents motion seeking the
production of the Non-Prosecution Agreement between the United Slates Attorney's Office for the
Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the
Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the
Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement,
including any modifications and addenda thereto, in accordance with the following procedures:
,
(a)
The USAO shall produce a copy of the Non-Prosecution Agreement,
including any modifications and addenda thereto (collectively referred to as the "Agreement"), to
the attorneys for Petitioners.
(h)
Petitioners and their attorneys shall not disclose the Agreement or its terms
to any third party absent further court order, following notice to and an opportunity for Epstein's
counsel to be beard.
(c)
Before counsel for petitioners show the Agreement to their clients or discuss
the specific terms with them, they must provide a copy of this Order to petitioners, who must review
and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for
petitioners must promptly provide a copy of that acknowledgment to the USAO.
(d)
If any individuals who have been identified by the USAO as victims of
EFTA00188559
12/08/2008 16:15 FAX
la 007/007
'
Case 9:08-cv-80736-KAM
Document 26
Entered on FLSD Docket 08/21/20O8
Page 2 of 2
Epstein and/or any attorney(s) for those individuals request the opportunity to review the
Agreement, then the USAO shall produce the Agreement to those individuals, so long as those
individuals also agree that they shall not disclose the Agreement or its terms to any third party
absent further court order, following notice to and an opportunity for Epstein's counsel to be heard
(e)
Prior to producing the documents to any other individuals who have been
identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy
of this Order must be provided to said individuals, who must review and acknowledge their receipt
of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly
provide a copy of that acknowledgment to the USAO.
DONE and ORDERED in Chambers, in West Pulm Beach, Palm Beach County, Florida,
this 21" day of August, 2008:
Copies furnished to: all counsel of record
Disigning below, l certify that I have reviewed and agree tote bound by the tenns of this
Order.
Dated: 91f GOS,
Signed by
Printed Name
2
EFTA00188560