EFTA00736311.pdf

(Rev.06,2005)Scakil Dammam Tracking Form UNITED STATES DISTRICT COURT Southern District of Florida Case Number: 08-CV-80893-MARRA-JOHNSON JANE DOE Plaintiff v. JEFFREY EPSTEIN Defendant SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal Name: Bradley J. Edwards Address: 425 N. Andrews Ave., Ste 2, Ft. Lauderdale, FL 33301 Telephone: 9545242820 On behalf of (select one): 0 Plaintiff ❑ Defendant Date sealed document filed: 7/2/2010 If sealed pursuant to statute, cite statute: If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain scaled until: O Conclusion of Trial ❑ Arrest ofFirst Defendant O Case Closing ❑ Conclusion ofDirect Appeal ❑ Other: O Permanently. Specify the authorizing law, rule, court order: The moving party requests that when the sealing period expires, the filed matter should be (select one): ❑ Unsealed and placed in the public portion of the court file ❑ Destroyed 0 Returned to the party or counsel for the party, as identified above Attorney for: EFTA00736311  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et at Defendant. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PLAINTIFF'S MOTION TO FILE PLAINTIFF JANE DOE'S EMERGENCY MOTION FOR A HEARING, FINDING THAT EPSTEIN IS IN CIVIL CONTEMPT OF THE COURT'S TWO ORDERS FORBIDDING HARASSMENT AND INDIRECT CONTACT, FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUDING REFERRAL FOR CRIMINAL CONTEMPT UNDER SEAL Plaintiff, Jane Doe, hereby moves this Court for an Order permitting Plaintiff Jane Doe's Emergency Motion for a Hearing, Finding that Epstein in Civil Contempt of the Court's Two Orders Forbidding Harassment and Indirect Contact for Appropriate Sanctions and Additional Remedies Including Referral for Criminal Contempt to be filed under seal and would state: Jane Doe requests this Emergency Motion be Filed Under Seal as Defendant, Epstein's blatant defiance of this Court no-harassment order appears to be designed by him to intimidate not only Jane Doe but also other witnesses in the case (i.e., other young girls that he sexually abused). The Sealing of this Motion is necessary to protect the safety of Jane Doe and other witnesses. EFTA00736312  CASE NO: 08-CV-80893-MARFtA/JOHNSON Therefore, the undersigned respectfully requests permission to file Jane Doe's Emergency Motion for a Hearing, Finding that Epstein in Civil Contempt of the Court's Two Orders Forbidding Harassment and Indirect Contact for Appropriate Sanctions and Additional Remedies Including Referral for Criminal Contempt Under Seal. DATED: July 2, 2010 Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: brad@pathtojustice.com and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: cassellp@law.utah.edu CERTIFICATE OF SERVICE I HEREBY CERTIFY a true and correct copy of the foregoing was sent via CM/ECF and U.S. mail on July 2, 2010 to: Robert D. Critton, Jr. BURMAN, CRITTON, et al. 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 2 EFTA00736313  CASE NO: 08-CV-80893-MARRAMOHNSON Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401 Counsel for Jeffrey Epstein Bradley J. Edwards 3 EFTA00736314  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 [Proposed] ORDER GRANTING PLAINTIFF'S MOTION TO FILE PLAINTIFF JANE DOE'S EMERGENCY MOTION FOR A HEARING, FINDING THAT EPSTEIN IS IN CIVIL CONTEMPT OF THE COURT'S TWO ORDERS FORBIDDING HARASSMENT AND INDIRECT CONTACT, FOR APPROPRIATE SANCTIONS AND ADDITIONAL REMEDIES INCLUDING REFERRAL FOR CRIMINAL CONTEMPT UNDER SEAL THIS CAUSE is before the Court upon Plaintiffs Motion to File Plaintiff Jane Doe's Emergency Motion for a Hearing, Finding that Epstein in Civil Contempt of the Court's Two Orders Forbidding Harassment and Indirect Contact for Appropriate Sanctions and Additional Remedies Including Referral for Criminal Contempt Under Seal. The Court has carefully considered the Motion and is otherwise fully advised in the premises. The Court finds a reasonable basis to allow the Motion and accompanying documents to be filed under seal. See S.D. Fla. L.R.5.4.B(2) ("any party seeking to make a filing under seal shall . . . [set] forth a reasonable basis for departing from the general policy of a public filing:). EFTA00736315  CASE NO: 08-CV-80893-MARRA/JOHNSON Accordingly, it is hereby ORDERED AND ADJUDGED as follows: 1. Plaintiffs Motion to File Plaintiff Jane Doe's Emergency Motion for a Hearing, Finding that Epstein in Civil Contempt of the Court's Two Orders Forbidding Harassment and Indirect Contact for Appropriate Sanctions and Additional Remedies Including Referral for Criminal Contempt Under Seal is hereby GRANTED. 2. The proposed documents are hereby sealed and shall remain permanently sealed. DONE AND ORDERED in West Palm Beach, Florida this day of , 2010. KENNETH A. MARRA United States District Judge cc: Counsel of record 2 EFTA00736316