EFTA00730290.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON JANE DOE, Plaintiff, v. JEFFREY EPSTEIN, Defendants. Joint Stipulation Plaintiff, JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their Joint Stipulation Regarding Certain Correspondence Obtained By Jane Doe's attorneys during discovery, and each state: I. In July 2010, the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos and Lehrman, PL. (the "Law Firm"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Plaintiff's Lawyers") received through discovery certain correspondence between Epstein's agents and federal prosecutors (the "Correspondence"). 2. With the exception of the Addendum to Settlement Agreement entered into in the above-styled matter and in the matters of M. vs. Epstein, CASE NO. 502008CA028051XXXXMB AB and vs. Epstein, CASE NO. 502008CA028058XXXXMB AD, The Law Firm and Plaintiff's Lawyers hereby agree that neither they nor their agents, lawyers, partners or employees will disseminate the Correspondence to any third parties including, but not limited to, news media, and will only use EFTA00730290 the Correspondence for purposes of the uses specifically outlined in paragraph 3 of the Addendums to Settlement referenced above and only after notice is given as provided for in paragraph 3 of the Addendums to Settlement. 3. To the extent the Law Firm or Plaintiff's Lawyers have additional lawsuits against Epstein, the information may be used in those lawsuits after 7 days notice is provided to Mr. Epstein. WHEREFORE, Plaintiff and Defendant requests that the Court enter an order on the above stipulation, and grant any additional relief the Court deems just and proper. Local Rule 7.1 Statement Pursuant to the above rule, the undersigned counsel and Plaintiff's counsel have conferred and have agreed to same. Respectfully submitted, By: Is/ Robert D. Critton, Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following service list in the manner specified via transmission of Notices of Electronic Filing generated by CMIECF on this _day of July, 2010: Brad Edwards, Esq. Jack Alan Goldberger, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos Atterbury Goldberger & Weiss, P.A. & Lehrman, PL 250 Australian Avenue South 425 N. Andrews Ave. Suite 1400 Suite #2 West Palm Beach, FL 33401-5012 Fort Lauderdale, FL 33301 ISM 2 EFTA00730291  Co-Counselfor Defendant Jeffrey Epstein Paul G. Cassell, Esq. Pro Hac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 By: Is/ Robert D. Critton, Jr. ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 (Co-Counselfor Defendant Jay Epstein) 3 EFTA00730292