EFTA00191264

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any-federal-eriminal-pnaseention=Edwards-Deelafation at 11 26. 
SO AGREED AND STIPULATED TO, THIS 
DAY OF DECEMBER, 2010. 
A-deems-it 
By: 
BRADLEY J. EDWARDS 
COUNSEL FOR PLAINTIFFS 
WIFREDO A. FERRER 
UNITED STATES ATTORNEY 
DEXTER LEE 
ASSISTANT U.S. ATI'ORNEY 
EFTA00191284

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No. 08-80736-Civ-Marra/Johnson 
JANE DOES #1 and #2 
I 
UNITED STATES 
STIPULATION 
The parties to this action, that is, Jane Doe #1, Jane Doe #2, and the United States of 
America, by and through their undersigned counsel, do hereby stipulate and agree that the 
following facts are true and correct and that no further evidentiary hearing is required with 
respect to the pending "Victim's Emergency Petition for Enforcement of Crime Victim 
Right Act, 18 U.S.C. § 3771. 
1. 
In 2006, at the request of the Palm Beach Police Department, the Federal 
Bureau of Investigation ("FBI") opened an investigation into allegations that Jeffrey 
Epstein ("Epstein") and his personal assistants had used facilities of interstate commerce to 
induce young girls between the ages of thirteen and seventeen to engage in prostitution, 
amongst other offenses. The case was presented to the United States Attorney's Office for 
the Southern District of Florida, which accepted the case for investigation. 
2. 
At the time that the investigation was opened, the Palm Beach County State 
Attorney's Office had presented evidence to a state grand jury, which had returned an 
EFTA00191285

indictment charging solicitation of prostitution. That charge made no reference to the 
ages of the minor victims and, upon conviction, did not require sex offender registration. 
3. 
Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with 
initials T.M. Both were victims of Epstein's while they were minors beginning when they 
were fifteen years old. Both Jane Does were identified through the Palm Beach Police 
Department's investigation of Epstein. 
4. 
Attached as Exhibits 1, 2, 3, and 4 to the Declaration of A. Marie Villafana 
are true and correct copies of victim notification letters sent to Jane Does 1 and 2 from the 
United States Attorney's Office and the FBI. 
5. 
Throughout the investigation, the FBI agents and the Assistant U.S. Attorney 
had several meetings with Jane Doe #1. During those meetings, Jane Doe #1 never 
expressed a desire to be consulted prior to the resolution of the investigation. Jane Doe #2 
was represented by counsel and, accordingly, all contact was made through that attorney. 
That attorney never expressed that Jane Doe #2 wanted to be consulted prior to the 
resolution of the investigation. 
6. 
In September 2007, Epstein and the U.S. Attorney's Office reached an 
agreement whereby the United States would defer federal prosecution in favor of 
prosecution by the State of Florida, so long as certain basic preconditions were met, those 
included a conviction on a state sex offense that reflected that the victims were minors at 
the time the crimes occurred and that would require sex offender registration. Another 
key objective for the United States Attorney's Office was to preserve a federal remedy for 
"2" 
EFTA00191286

the young girls whom Epstein had sexually exploited. The Agreement contained an 
express confidentiality provision. The Agreement was subsequently modified in October 
and December 2007. 
7. 
Although individual victims were not consulted regarding the agreement, 
several had expressed concerns regarding the exposure of their identities at trial and they 
desired a prompt resolution of the matter. 
At the time the agreement and the 
modifications were signed in September, October, and December 2007, Jane Doe #2 was 
openly hostile to the prosecution of Epstein. 
8. 
In October 2007, shortly after the initial agreement was signed, Jane Doe # I 
was contacted to be advised regarding the resolution of the investigation. On October 
2007, Special Agents E. Nesbitt Kuyrkendall and Jason Richards met in person with Jane 
Doe #1. The Special Agents explained that the investigation had been resolved, that 
Epstein would plead guilty to two state offenses, he would be required to register as a sex 
offender for life, and he had made certain concessions related to the payment of damages to 
the victims, including Jane Doe #1. Jane Doe #1 also was advised that Epstein would be 
entering a guilty plea in state court on October __, 2007, although the October change of 
plea did not take place. During this meeting, Jane Doe #1 did not raise any objections to 
the resolution of the matter. 
9. 
Jane Doe #1 misunderstood the explanation provided by the Special Agents, 
believing that only the State part of the Epstein investigation had been resolved, and that 
the federal investigation would continue, possibly leading to a federal prosecution. 
EFTA00191287

10. 
When Epstein's attorneys learned that some of the victims had been notified, 
they complained that the victims were receiving an incentive to overstate their involvement 
with Epstein in order to increase their damages claims. Following the signing of the 
Agreement and the modifications thereto, Epstein's performance was delayed while he 
sought to rescind the Agreement. Throughout that period, the FBI and the U.S. Attorney's 
Office maintained contact with the victims, to be prepared if Epstein were to renege on the 
agreement. 
11. 
After Jane Doe # I had been notified of the terms of the agreement, but before 
Epstein performed his obligations, Jane Doe #1 contacted the FBI because Epstein's 
counsel was attempting to take her deposition and private investigators were harassing her. 
Assistant U.S. Attorney A. Marie Villafafta secured pro bono counsel to represent Jane 
Doe #1 and several other identified victims in connection with the criminal investigation. 
Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. 
12. 
In mid-June 2008, Attorney Edwards contacted AUSA Villafafia to inform 
her that he represented Jane Doe #1 and, later, Jane Doe #2. Attorney Edwards asked to 
meet to provide information regarding Epstein. Attorney Edwards was asked to send any 
information that he wanted considered, but did not send anything. 
13. 
On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia 
received a copy of Epstein's proposed state plea agreement and learned that the plea was 
scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafafta and the Palm Beach 
Police Department attempted to provide notification to victims in the short time that 
"4" 
EFTA00191288

Epstein's counsel had provided. Attorney Edwards was called to provide notice to his 
clients regarding the hearing. 
14. 
On July 9, 2008, AUSA Villafafia sent a victim notification to Jane Doe #1 
via her attorney, Bradley Edwards, which is attached as Exhibit 6 to the Villafafia 
Declaration. That notification contains a written explanation of the full terms of the 
agreement between Epstein and the U.S. Attorney's Office. A notification was not 
provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom 
the United States was prepared to name in an indictment. 
SO STIPULATED AND AGREED. 
Dated: 
BRADLEY EDWARDS, ESQ. 
Attorney for Plaintiffs Jane Does #1 & 2 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
ASSISTANT 
U.S. 
ATTORNEY 
DEXTER LEE 
Attorney for Defendant United States 
-5-
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 1 of 13 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA/JOHNSON 
JANE DOE #1 and JANE DOE #2, 
Plaintiffs, 
1. 
UNITED STATES OF AMERICA, 
Defendant, 
ROY BLACK, et al., 
Intervenors. 
/ 
INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY 
ORDER AND INCORPORATED MEMORANDUM OF LAW 
Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) 
of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court 
for the entry a Protective Confidentially Order which (1) limits the dissemination of certain 
Confidential Discovery Material ("CDM") described below, to a designated list of the 
Plaintiffs' counsel and support staff, and (2) prohibits any party from filing pleadings, briefs, 
memorandums or exhibits purporting to reproduce, quote, paraphrase or summarize any 
CDM or portions thereof, absent leave of the Court to file the document or portion thereof 
under seal in accordance with Local Rules of the United States District Court for the 
Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order. 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 2 of 13 
In support of this motion, the Intervenors submit the following Memorandum. Part I 
sets forth the background of this matter. Part II demonstrates why the Court can and should 
issue the requested protective order. 
MEMORANDUM 
I. BACKGROUND 
Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with 
the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two 
state felony offenses and served a prison sentence and a term of community control 
probation. The agreement, with which he has fully complied, also required that he pay the 
legal fees of the attorney-representative of identified victims and that he not contest liability 
in any cases brought against him solely under 18 U.S.C. § 2255. Plaintiffs sued under § 2255 
and received settlements as the direct result of Mr. Epstein's agreement not to contest 
liability in those cases. Plaintiffs, such as the Jane Does in this case, "relied on the [NPA] 
when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the 
[NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to 
Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. 
After reaping the benefits of the NPA, the plaintiffs seek herein, among other 
remedies, the rescission of that agreement. During the course of civil litigation against Mr. 
Epstein, Mr. Epstein was ordered, over his strenuous objection, to produce documents given 
to him by the government during the course of his settlement/plea negotiations with it. See 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 3 of 13 
Jane Doe #2'. Epstein, No. 08-80119-MARRA, Doc. 462. Once the CVRA action was 
reactivated — after plaintiffs had successfully pursued their civil monetary remedies against 
Mr. Epstein to completion — plaintiffs sought to use that correspondence in the CVRA case 
and thereafter also sought disclosure from the government of correspondence authored and 
sent to the government by Mr. Epstein's attorneys in the course of their efforts on behalf of 
their client to resolve the ongoing criminal investigation of him. Both Mr. Epstein and his 
criminal defense attorneys - Intervenors Roy Black and Martin Weinberg — filed motions to 
intervene for the limited purpose of challenging the use and disclosure of the settlement/plea 
negotiation correspondence (Doc. 56, 93), followed by supplemental briefing and motions 
contending, among other things, that the correspondence fell within the bounds of privilege 
under Fed. R. Evid. 501. Doc. 94, 160,161, 162. 
This Court granted the motions to intervene (Doc. 158, 159), but ultimately ruled that 
the correspondence — the CDM at issue in the instant motion — was subject to disclosure. 
Doc. 188. Among other things, the Court rejected Intervenors' argument based on Rule 501 
on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and 
Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a 
privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the 
Court's ruling to the Eleventh Circuit. However, on April 14, 2014, the Eleventh Circuit 
affirmed the Court's rulings using the same rationales. 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 4 of 13 
II. 
ARGUMENT 
Although the Court ruled that the Plaintiffs could discover the CDM, the Court 
reserved ruling on how the Plaintiffs could use the material thereafter, expressly cautioning 
that "this order is not intended to operate as a ruling on the relevance or admissibility of any 
particular piece of correspondence, a matter expressly reserved for determination at the time 
of final disposition." Doc 188, p. 10. Unless and until the Court determines those reserved 
issues, the Court should bar the Plaintiffs from disseminating and/or publicly disclosing the 
substance of the CDM absent further order of the Court. 
A. 
Discovery Should Not Be Routinely Made Available to the Public 
"The Eleventh Circuit has repeatedly acknowledged the private nature of discovery" 
Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. 
LEXIS 48349, at *3, citing Chicago Tribune Co. 
Bridgestone/Firestone, Inc., 263 F.3d 
1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private 
process because the litigants and the courts assume that the sole purpose of discovery is to 
assist trial preparation.") (quoting United States'. Anderson, 799 F.2d 1438, 1441(11'h Cir. 
1986; emphasis in original). See also Anderson, 799 F.2d at 1441 ("Historically, discovery 
materials were not available to the public or press.") (citation omitted); In re: Denture 
Cream Products Liability Litigation, No. 09-2051-MD-Altonaga/Simonton (S.D. Fla. Jan. 
18, 2013), 2013 U.S. Dist. LEXIS 8114, at *37 ("the common law right of access to judicial 
proceedings does not apply to discovery materials, `as these materials are neither public 
-4-
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 5 of 13 
documents nor judicial records') (quoting Chicago Tribune, 263 F.3d at 1311; citation 
omitted). Thus, "[a] court may restrict distribution of discovery material even if there 
'certainly is a public interest in knowing more' about its contents." Tillman'. C.R. Bard, 
Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Ha. March 13, 2014), 2014 U.S. Dist. LEXIS 
41406, at *6, quoting Seattle Times Co.'. Rhinehart, 467 U.S. 20, 31 (1984) 
Placing limitations on the dissemination and use of pretrial discovery is particularly 
important since "[t]he overwhelming majority of documents disclosed during discovery are 
likely irrelevant to the underlying issues...." Federal Trade Commission. Abbvie Products 
LLC, 713 F.3d 54, 63 (11'"  Cir. 2013). Therefore, "[s]uch documents, prior to admission into 
the record in support of a motion or as evidence at trial, 'play no role in the performance of 
Article III functions' of a federal judge." Travelers Indemnity Co.. Excalibur Reinsurance 
Corp., No. 3:1 I-CV-1209 (CSH) (D. Conn. Aug. 5, 2013), 2013 U.S. Dist. LEXIS 110400, 
at *37, quoting United States', Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995). 
These principles are vitally important here where counsels' private communications 
with prosecutors "if publicly released could be damaging to reputation and privacy" and 
would likely constitute an "abuse of [a court's] processes." Seattle Times, 467 U.S. at 35 
While courts have recognized that settlement agreement materials may sometimes be 
discoverable, see, e.g., In re MSTG, Inc., 675 F.3d 1337, 1348 (Fed. Cir. 2012),' they are 
But see Wagner'. Wash{/)`, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist. 
LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds); 
Duncan' Phoenix Supported Living, Inc., No. 2:05cvl (W.D. N.C. Sept. 12, 2006), 2006 U.S. Dist. 
(continued...) 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 6 of 13 
rarely admissible as evidence at trial, see, e.g, LaserDynamics. Inc. 
Quanta Computer, 
Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement 
agreement at trial); Apple, Inc.'. Samsung Electronics Co., Ltd., Case No. 1 -CV-01846-
LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at "51-54 (barring parties 
from relying on settlement agreement at trial under Fed. R. Evid. 403). 
For this reasons alone, it is appropriate to limit the dissemination and use of discovery 
concerning settlement discussions, even if not privileged. See Charles E. Hill & Associates, 
Inc. I. ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating 
discovery material including settlement communications as "Outside Counsel Eyes Only 
Confidential Information" and cautioning parties that while it is allowing the discovery it 
intends to later weigh relevance carefully and noting that settlement negotiations are "always 
suspect to some degree and are often littered with unreal assertions and unfounded 
expectations ... And are not always grounded in facts or reason."). Indeed, unless and until 
the Plaintiffs demonstrate a bona fide need to use the discovery at trial or in pleadings, the 
Intervenors need not even demonstrate "good cause" in order to obtain relief. As the Hon. 
Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of 
Alabama recently held: 
'(...continued) 
LEXIS 66742, at "9-11 (finding settlement communications non-discoverable as "not .. Likely to 
lead to the disclosure of admissible evidence" and would tend to chill settlement efforts) (citations 
omitted). 
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Based on this standard of practice, the court finds that restricting 
the use of discovery materials to case-related purposes only, 
even over Plaintiffs' objection, is within this court's discretion 
and authority even without the application of the Rule 26(c) 
good cause standard. By its text, Rule 26(c) applies to situations 
where the court is either limiting what a party has to produce at 
all in the discovery process, or limiting public access to 
documents that are actually filed in the case. Fed. R. Civ. Pro. 
26(c). The disputed limitation in this case does not fall into 
either of these categories.... 
Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. 
LEXIS 48349, at ** 4-5 (emphasis in original). 
B. 
Good Cause Exists For the Protective Order In Any Event 
Even if the Intervenors would be required to demonstrate "good cause" for the 
requested protective order at this point, that standard is met where restrictions are appropriate 
under Rule 26(c) to protect the Intervenors from "annoyance, embarrassment, oppression, 
or undue burden or expense." See Looney, 2014 U.S. Dist. LENS 48349, at *5; Irizarry-
Santiago'. Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include 
not only the third-party client whose non-prosecution agreement is the one Plaintiffs are 
trying to undo but also the client's attorneys, who are even further removed from the actual 
litigants. Counsels' lengthy arguments may or may not have had any influence on the 
government's decision-making and, therefore, their relevance is particularly remote. CI 
United States'. Byrd, Crim. No. 13-0266-WS (S.D. Ala. April 7, 2014), 2014 U.S. Dist. 
LEXIS 48035, at "14-18 (denying newspaper's motion to obtain copies of unsolicited 
sentencing letters mailed to the judge prior to sentencing, despite "no formal promises of 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 8 of 13 
secrecy or confidentiality," because "the privacy interests of the letter writers and the 
interests of the judicial system in obtaining hones, uncensored input" outweighed public's 
interest in disclosure, especially where the sentencing letters "neither drove no significantly 
impacted the sentencing decision" which was based on a plea agreement). 
Like the situation at issue in Looney, the instant case is a "high profile" one and 
should not be "tried in the media, rather [than] in the courtroom." Looney, 2014 U.S. Dist. 
LEX1S 48349, at *5. Moreover, there is a well documented history in this case of the media 
reporting inflammatory statements made by Plaintiffs' counsel, either directly to the press or 
in pleadings, and these statements have frequently been based on discovery materials. See, 
e.g., Attorneys Say Miami Prosecutors Violated Crime Victims' Rights Act, Main Justice, 
March 22, 2011 (quoting Plaintiffs' motion asserting that the U.S. Attorney's Office 
"deliberately misled' them and claiming that the "only reason" the U.S. Attorney's Office 
"concealed the existence of the non-prosecution agreement from them was "to avoid a 
firestorm of public controversy that would have erupted if the sweetheart plea dal with a 
politically connected billionaire had been revealed"); Attorneys want Jeffrey Epstein 
agreement thrown out, PalmBeachDailyNews.com, March 21, 2011 (repeating 
aforementioned accusations from Plaintiffs' motion attacking the U.S. Attorney's Office, 
adding that the Office had allegedly engaged in a "pattern of deception" and noting that 
Plaintiffs' motion had made references to "e-mails and letters from the federal office to 
Epstein's lawyers"); News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 9 of 13 
Importance of Victims Rights, BriefingWire.com, March 8, 2011 (quoting Plaintiffs' counsel 
saying "we took on powerful people and sought to level the playing field to protect victims" 
and that he "hopes that the media attention" will "inspire victims" to "hold predators 
accountable"); Judge Receives Epstein Tape Ruling Pending, Palm Beach Daily News, May 
5, 2010 (quoting plaintiffs' counsel as arguing that a 22-minute tape recording of Mr. Epstein 
was "'critical" in showing his alleged "'lack of remorse" and that he was a "pitiless" sexual 
abuser); Lawyer: Epstein Made Admissions On Tape, Palm Beach Daily News (FL), April 
29, 2010 (quoting Plaintiffs' motion concerning the same tape recording); Attorney For 
Epstein Victims: 'I have Never Seen A Stranger Case', Palm Beach Daily News, September 
20, 2009, p. A.1 (quoting Plaintiffs' counsel as opining that Mr. Epstein "could have gone 
to prison for life," that he had "never seen a stranger case" and that the U.S. Attorney's 
Office was effectively "saying we'll do everything in our power to see he doesn't get 
punished"); Palm Beach sex offender's secret plea deal: Possible co-conspirators not 
charged, presses victims to settle civil suits, The Palm Beach Post, September 18, 2009 
(quoting Plaintiffs' counsel as saying that non-prosecution agreement "taught [the victims] 
that someone with money can buy his way out of anything. It's outrageous and 
embarrassing...."); Judge to Rule on Sealed Plea-Deal Papers Today, Palm Beach Daily 
News, June 25, 2009, p. A.1 (reporting Plaintiffs' counsel saying that he wanted to use the 
settlement documents in depositions); Hearing Set to Consider Secrecy of Plea Bargain, 
Sun-Sentinel (Ft. Lauderdale, Florida), Palm Beach Edition, June 15, 2009, p. 38 (in 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 10 of 13 
response to reporter's question about whether he thought Mr. Epstein had received special 
treatment, Plaintiffs' counsel quoted as saying: "Are you kidding? It's transparent. 
Certainly, no one else gets treated like that"). See Composite Exhibit 2. 
The publicity-generating comments by Plaintiffs' counsel have continued since the 
Eleventh Circuit's ruling. The wave began on April 21, 2014. That day, the Washington 
Post published a lengthy letter written by one of Plaintiffs' lead counsel containing his 
editorialized history of the case criticizing the Intervenors' arguments and concluding with 
his opinion that "the federal prosecutors deliberately concealed the sweetheart plea deal." 
See Composite Exhibit 3. The same attorney was also quoted by the Sun-Sentinel as making 
the unsupported accusation that somehow Mr. Epstein "used his political connections and 
great wealth" to secure a plea bargain that, in counsel's opinion "was unheard of, frankly, if 
you look at these charges." Id. Also that same day, the Plaintiffs' other lead counsel was 
quoted by the Palm Beach Daily News as referring to Mr. Epstein as "[a] well-connected 
billionaire" who "got away with molesting many girls." Appeals court rules against sex 
offender; Attorneys for underage victims seek to overturn 
'sweetheart plea', 
PalmBeachDailyNews.com, April 21, 2014. Id. 
On April 22, 2014, the same attorney issued a "press release" likewise trumpeting the 
appellate victory, identifying Mr. Epstein's counsel by name and containing a personal 
statement from counsel. See Composite Exhibit 4. In a parallel article published in the 
Daily Business Review, Plaintiffs' counsel was quoted as follows: "Edwards said the 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 11 of 13 
documents at this point will be disclosed only to the plaintiffs and will not become part of 
the public record." Id. (emphasis added). The implication of the "at his point" qualifier 
suggests that Plaintiffs' counsel plan to inject the private discovery into "the public record" 
at a later date. 
The next day, April 23, 2014, the Facebook page for the Farmer Jaffe Weissing law 
firm began posting multiple photographs of Mr. Epstein with links to numerous newspaper 
articles about the case, along with snippets of prejudicial quotations from Plaintiffs' counsel. 
See Composite Exhibit 5. The same comments were then posted on the law firm's blog 
"www.pathtojustice.com with yet another large photograph of Mr. Epstein, resembling a mug 
shot. Id. The blog includes such personalized opinions, such as: "We have a very strong 
case that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart 
plea deal." Id. 
In light of the prominence of this case in the media, the repeated use of the media by 
Plaintiffs counsel to drum up support for their case (and to prejudice the community against 
Mr. Epstein and his counsel), and the Plaintiffs' suggestion that they could make the CDM 
available to the public in the future (just not "at this point"), the requested protective order 
is more than justified. As Chief Judge Bowdre likewise concluded in a similar, but less 
egregious, situation: 
The court has already expressed to the parties its concern that 
this potentially high profile case will be tried in the media, rather 
in the courtroom. Significant media coverage of the case has 
already occurred. In the interest of justice, this court is 
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Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 12 of 13 
committed to giving both parties a fair trial, which includes 
protecting the Defendants from the "annoyance, embarrassment, 
[and] oppression" that could occur from allowing their names to 
be dragged through the metaphorical mud before a jury has even 
made any determination of wrongdoing. At least one other court 
has cited the risk of excessive publicity preventing the selection 
of an impartial jury as legitimate sup in for a finding of good 
cause under Rule 26(c). See Anderson Cryovac, Inc., 805 F.2d 
I, 4 (1st Cir. 1986) (overturning the district court's decision on 
other grounds). As such, the court finds that good cause exists 
to support the Protective Order as written.... 
Looney'. Moore, 2014 U.S. Dist. LEXIS 48349, at "5-6. 
LOCAL RULE 7.1(a)(3) CERTIFICATION 
Counsel hereby certify that they have conferred with all parties who may be affected 
by the relief sought in this motion in a good faith effort to resolve the issues raised in the 
motion and have been unable to do so. Plaintiffs oppose this motion. 
CONCLUSION 
For all of the foregoing reasons, the Court should GRANT this motion and enter the 
requested Protective Order. 
Respectfully submitted, 
/s/Roy Black 
Roy Black 
Jackie Perczek 
BLACK, SREBNICK, KORNSPAN 
& STUMPF, P.A. 
201 So. Biscayne Blvd., Suite 1300 
Miami, Florida 33131 
Tele: (305) 371-6421 
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Case 9 08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 13 of 13 
Fax: (305) 358-2006 
rblackQrovblack.com 
joerczekQrovblack.com 
Attorneys for Intervenors 
/s/Martin G. Weinberg 
Martin G. Weinberg 
20 Park Plaza, Suite 1000 
Boston, Massachusetts 02116 
Tele: (617) 227-3700 
Fax: (617) 338-9538 
owlmgw(aatt.net 
Attorney for Intervenors 
CERTIFICATE OF SERVICE 
I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this 
2ad day of May, 2014. 
/s/Rov Black 
Roy Black 
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Case 9:08,,80736-KAM Document 247-4 Entered on FLSD Docket 05/02/2014 Page 1 of 6 
COMPOSITE EXHIBIT 4 
EFTA00191303