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Subject: Judge Marra's Rulings in the Jane Doe v. Epstein litigation

Subject: Judge Marra's Rulings in the Jane Doe v. Epstein litigation Date: Tue, 05 Aug 2008 14:12:57 +0000 Importance: Normal Attachments: DE34_080805_Order_Denying_Motn_to_Seal.pdf; DE33_080805_Order_Denying_Motn_to_Stay.pdf Good morning. Judge Marra is keeping Mr. Epstein's attorneys on their toes. This morning he issued two rulings in one of the civil suits. First, he denied Epstein's motion to stay the civil litigation, finding that there is no pending "criminal action" based upon the Non-Prosecution Agreement. He includes a wonderful line, "After all, Defendant is in control of his own destiny — it is up to him (and him alone) whether the plea agreement reached with the State of Florida is breached." Judge Marra also denied Epstein's Motion to Seal his Reply Brief on the Motion to Stay. The Clerk's Office has not yet unsealed those documents, but it is possible that they contain the Non-Prosecution Agreement, which would make tomorrow's meeting much easier. I will chec

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Subject: Judge Marra's Rulings in the Jane Doe v. Epstein litigation Date: Tue, 05 Aug 2008 14:12:57 +0000 Importance: Normal Attachments: DE34_080805_Order_Denying_Motn_to_Seal.pdf; DE33_080805_Order_Denying_Motn_to_Stay.pdf Good morning. Judge Marra is keeping Mr. Epstein's attorneys on their toes. This morning he issued two rulings in one of the civil suits. First, he denied Epstein's motion to stay the civil litigation, finding that there is no pending "criminal action" based upon the Non-Prosecution Agreement. He includes a wonderful line, "After all, Defendant is in control of his own destiny — it is up to him (and him alone) whether the plea agreement reached with the State of Florida is breached." Judge Marra also denied Epstein's Motion to Seal his Reply Brief on the Motion to Stay. The Clerk's Office has not yet unsealed those documents, but it is possible that they contain the Non-Prosecution Agreement, which would make tomorrow's meeting much easier. I will chec

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Subject: Judge Marra's Rulings in the Jane Doe v. Epstein litigation Date: Tue, 05 Aug 2008 14:12:57 +0000 Importance: Normal Attachments: DE34_080805_Order_Denying_Motn_to_Seal.pdf; DE33_080805_Order_Denying_Motn_to_Stay.pdf Good morning. Judge Marra is keeping Mr. Epstein's attorneys on their toes. This morning he issued two rulings in one of the civil suits. First, he denied Epstein's motion to stay the civil litigation, finding that there is no pending "criminal action" based upon the Non-Prosecution Agreement. He includes a wonderful line, "After all, Defendant is in control of his own destiny — it is up to him (and him alone) whether the plea agreement reached with the State of Florida is breached." Judge Marra also denied Epstein's Motion to Seal his Reply Brief on the Motion to Stay. The Clerk's Office has not yet unsealed those documents, but it is possible that they contain the Non-Prosecution Agreement, which would make tomorrow's meeting much easier. I will check before our conference call. Thank you. EFTA00215872

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Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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