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efta-efta00234745DOJ Data Set 9Other

Case 9:08-cv-80893-KAM

Case 9:08-cv-80893-KAM Document 3 Entered on FLSD Docket 08/14/2008 %le FILPIage 1 %B1 D.C. ELECTRONIC JANE DOE, Plaintiff vs. JEFFREY EPSTEIN, Defendant A UGUST 13, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 0 gCV g .°S2193 /Mtn / LRJ 08-80893-Civ-MARRA/JOHNSON STEVEN M. LARIMORE CLERK U.S. 01ST. CT. 5. D. OF FLA. • MIAMI FILED by AUG 13 2008 STEVEN M. LARIMORE CLERK U.S. 0151: CT S.O. OF FLA. • W P.S. D.C. MOTION TO KEEP TRUE NAME IN SEALED ENVELOPE The Plaintiff, Jane Doe, moves this Court that, due to the sensitive nature of the matters contained in the accompanying Complaint, the true name affidavit of Jane Doe, a pseudonym, presented to the Court concurrently with this Motion, be held by the Court in a sealed envelope to preserve the anonymity of the Plaintiff, Jane Doe, and that the Plaintiff, Jane Doe, be allowed to continue in this case under this pseudonym on the ground that revelation of the Plaintiff, Jane D

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DOJ Data Set 9
Reference
EFTA 00234745
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1
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2
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Case 9:08-cv-80893-KAM Document 3 Entered on FLSD Docket 08/14/2008 %le FILPIage 1 %B1 D.C. ELECTRONIC JANE DOE, Plaintiff vs. JEFFREY EPSTEIN, Defendant A UGUST 13, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 0 gCV g .°S2193 /Mtn / LRJ 08-80893-Civ-MARRA/JOHNSON STEVEN M. LARIMORE CLERK U.S. 01ST. CT. 5. D. OF FLA. • MIAMI FILED by AUG 13 2008 STEVEN M. LARIMORE CLERK U.S. 0151: CT S.O. OF FLA. • W P.S. D.C. MOTION TO KEEP TRUE NAME IN SEALED ENVELOPE The Plaintiff, Jane Doe, moves this Court that, due to the sensitive nature of the matters contained in the accompanying Complaint, the true name affidavit of Jane Doe, a pseudonym, presented to the Court concurrently with this Motion, be held by the Court in a sealed envelope to preserve the anonymity of the Plaintiff, Jane Doe, and that the Plaintiff, Jane Doe, be allowed to continue in this case under this pseudonym on the ground that revelation of the Plaintiff, Jane D

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Case 9:08-cv-80893-KAM Document 3 Entered on FLSD Docket 08/14/2008 %le FILPIage 1 %B1 D.C. ELECTRONIC JANE DOE, Plaintiff vs. JEFFREY EPSTEIN, Defendant A UGUST 13, 2008 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 0 gCV g .°S2193 /Mtn / LRJ 08-80893-Civ-MARRA/JOHNSON STEVEN M. LARIMORE CLERK U.S. 01ST. CT. 5. D. OF FLA. • MIAMI FILED by AUG 13 2008 STEVEN M. LARIMORE CLERK U.S. 0151: CT S.O. OF FLA. • W P.S. D.C. MOTION TO KEEP TRUE NAME IN SEALED ENVELOPE The Plaintiff, Jane Doe, moves this Court that, due to the sensitive nature of the matters contained in the accompanying Complaint, the true name affidavit of Jane Doe, a pseudonym, presented to the Court concurrently with this Motion, be held by the Court in a sealed envelope to preserve the anonymity of the Plaintiff, Jane Doe, and that the Plaintiff, Jane Doe, be allowed to continue in this case under this pseudonym on the ground that revelation of the Plaintiff, Jane Doe's identity would cause severe personal, professional and economic consequences. The Plaintiff, Jane Doe, attaches in support of this motion a memorandum of law and an affidavit. Dated: August 12, 2008 Respectfully submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards Florida Bar #542075 1:12 Hollywood, Florida 33020 Phone: Fax: I of 1 EFTA00234745

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Case #9:08-CV-80893-KAM

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DOJ Data Set 9OtherUnknown

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen

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Case 9:08-cv-80736-KAM

Case 9:08-cv-80736-KAM Document 28 Entered on FLSD Docket 09/25/2008 Page 1 of 8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. VICTIM'S MOTION TO UNSEAL NON-PROSECUTION AGREEMENT COMES NOW the Petitioners, Jane Doe #1 and Jane Doe #2, by and through their undersigned attorneys, pursuant to the Crime Victim's Rights Act, 18 U.S.C. Section 3771 ("CVRA"), and file this motion to unseal the non-prosecution agreement that has been provided to their attorneys under seal in this case. The agreement should be unsealed because no good cause exists for sealing it. Moreover, the Government has inaccurately described the agreement in its publicly-filed pleadings, creating a false impression that the agreement protects the victims. Finally, the agreement should be unsealed to facilitate consultation by victims' counsel with others involved who have

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