027.pdf

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Extraction Summary

20
People
11
Organizations
10
Locations
2
Events
5
Relationships
4
Quotes

Document Information

Type: Court filing - motion for leave to file under seal
File Size: 50.1 KB
Summary

This document is a Motion for Leave to File Under Seal submitted on May 29, 2009, by attorneys for Plaintiffs Jane Doe No. 101 and 102 in the Southern District of Florida. The plaintiffs request permission to file their response to Epstein's Motion to Stay under seal, or alternatively, request the court to unseal the Non-Prosecution Agreement (NPA) so they can adequately respond. The document includes a comprehensive service list detailing attorneys representing Epstein, co-defendant Sarah Kellen (represented by Bruce Reinhart), and various other Jane Doe plaintiffs.

People (20)

Name Role Context
Jeffrey Epstein Defendant
Defendant in multiple civil cases listed in the document
Jane Doe No. 101 Plaintiff
Plaintiff filing motion to seal response or unseal NPA
Jane Doe No. 102 Plaintiff
Plaintiff filing motion to seal response or unseal NPA
Sarah Kellen Co-Defendant
Represented by Bruce E. Reinhart
Katherine W. Ezell Attorney
Attorney for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (Podhurst Orseck)
Robert C. Josefsberg Attorney
Attorney for Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (Podhurst Orseck)
Robert Critton Attorney
Counsel for Defendant Jeffrey Epstein
Michael J. Pike Attorney
Counsel for Defendant Jeffrey Epstein
Jack Goldberger Attorney
Co-Counsel for Defendant Jeffrey Epstein
Bruce E. Reinhart Attorney
Counsel for Co-Defendant Sarah Kellen
Jack Scarola Attorney
Counsel for Plaintiff C.M.A.
Jack P. Hill Attorney
Counsel for Plaintiff C.M.A.
Adam Horowitz Attorney
Counsel for Plaintiffs in Related Cases
Stuart Mermelstein Attorney
Counsel for Plaintiffs in Related Cases
Spencer Todd Kuvin Attorney
Counsel for Plaintiff in Related Case No. 08-08804
Theodore Jon Leopold Attorney
Counsel for Plaintiff in Related Case No. 08-08804
Richard Willits Attorney
Counsel for Plaintiff in Related Case No. 08-80811
Brad Edwards Attorney
Counsel for Plaintiff in Related Case No. 08-80893
Isidro Manuel Garcia Attorney
Counsel for Plaintiff in Related Case No. 08-80469
C.M.A. Plaintiff
Plaintiff in related case 08-CV-80811

Timeline (2 events)

2008-08-21
Order to Compel Production and Protective Order entered
Southern District of Florida
2009-05-29
Filing of Motion for Leave to File Under Seal
United States District Court Southern District of Florida

Relationships (5)

Jeffrey Epstein Legal Adversary Jane Doe No. 101
Plaintiff vs Defendant in case 09-CV-80591
Jeffrey Epstein Legal Adversary Jane Doe No. 102
Plaintiff vs Defendant in case 09-CV-80656
Sarah Kellen Attorney-Client Bruce E. Reinhart
Service list lists Bruce E. Reinhart as 'Counsel for Co-Defendant, Sarah Kellen'
Jeffrey Epstein Attorney-Client Robert Critton
Service list lists Robert Critton as 'Counsel for Defendant, Jeffrey Epstein'
Jeffrey Epstein Attorney-Client Jack Goldberger
Service list lists Jack Goldberger as 'Co-Counsel for Defendant, Jeffrey Epstein'

Key Quotes (4)

"The Protective Order prohibits Plaintiffs from disclosing the Non-Prosecution Agreement (the 'NPA') or its terms to any third party."
Source
027.pdf
Quote #1
"Undersigned counsel seek to file this Response in Opposition to Defendant Jeffrey Epstein’s Motion to Stay under seal in order to abide by this Court’s August 21, 2008 Order"
Source
027.pdf
Quote #2
"In the alternative, Plaintiffs respectfully request this Court to unseal the Non-Prosecution Agreement in order to allow Plaintiffs to concretely respond to Defendant’s Motion to Stay."
Source
027.pdf
Quote #3
"Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 would then have 'a specific tangible need to be relieved of the restrictions' of the Protective Order because consideration of the terms of the NPA is necessary for this Court to resolve Defendant’s Motion to Stay."
Source
027.pdf
Quote #4

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