UNITED DISTRICT DISTRIC-4.1T-.3 OF CASE NO 08-80736-CIV-MARRA/JOHNSON JANE DOE and JANE DOE Plaintiffs UNITED OF AMERICA,-6.1 Defendant I PS-5.5TEIN NOP-7.4P-2OSED OTION OR A UPPLE-4.6M-1ENTAL ROTECTIVE RD3.1ER 10Now 180Intervenor 180Jeffrey stein who moves that this Honorable Court issue a sup5.5p.5lem8.3e-.7ntal Protective Order that would expand the lim8ited Protective Order allowed in its decision Granting in and De in the In6.2terven6.2ors Mo6.2tion a5 Protective Confidentiality Or der D.E at The purpose of the proposed supplem8.2ent to the previously or dered Protective Order is to require that any party would be required to file under eal any portion of the plea nego tiation correspo ndence between the Governm8.2e-.8nt and Epstein?s counsel whethe offered as an exhibit or quoted from in the content of a pleading or m8.5o.7tion Such a re dacted filing would in all other respects be filed as a public filing u5.6n.6less subject to othe orders of the Court and each party would5.5 reserve the right to to unseal any reda cted pleading or seal ed exhibit After consultation with their counsel both the Plai ntiffs and the Governm8.1e-.9nt do not oppose the allowing of this Motion Case Document Entered on FLSD Docket Page of Respectf3.9u.9lly5.9 subm8.7itted JEFFREY E-4.5PSTEIN By His Attorneys,5.4 s/Roy Black Roy Black Jackie Perczek BLAC-3.6K SR-3.6EBNICK KORNS-4.4P.6AN STUMPF So Biscayne Blvd Suite Miam8.3i Florida Tele Fax rblack 6.3r-1.6oyblack.com jperczek royblack.com s/Ma5.5r-.7tin Weinberg Martin Weinberg Park Plaza Suite Boston Massachusetts Tele Fax a-7.1tt.net CERTIFICATE OF I HERE CERTIFY that a true copy of th foregoing was filed via CM/E6.1CF this th day of October s/Roy Black Roy Black Case Document Entered on FLSD Docket Page of
