DI-6.9STRICT COURT-4.1 10650SOUTHERN DIST-3.4RI-6.2CT OF FL-3.4ORIDA No 9:08-80736-Civ-Marra/Johnson JANE DOE and JANE DOE UNITE-4.9D JANE NO AND JANE DOE NO NOTICE OF WITHDRAW-5.7AL OF REQUES-4.6T FOR FURT-3.8HER NAM-7ES FROM THE NOW Jane Doe No and Jane Doe No the petitioners by and through undersigned counsel to file this notice that that they have conferred with the Governm8.4e-.6nt and obtained the inform8.5ation that they need at this tim8e about the nam8e-1s of individuals that the confirm7.9e-1.1d be Jeffrey Epstein?s se abuse victim8.2s-5.4 at the it negotiated the non prosecution agreem8.3ent NPA Court had orde4.5red5.7 the Govern5.7m8.5e-.5nt to conf4er with pe4.8tition6e-.2rs5.2 co6unsel regard6ing6 disclosure of Jeffrey Epstein?s victim7.5s DE at The Governm8.1e-.9nt conferred with counsel and that conferral confirmed in genera term7.9s that petitioners counsel already had knowledge of the of the pers ons the Governm7.9e-1.1nt identified to be victim8.1s And indeed the conferral indicated that petitione rs counsel had knowledge of the of other victim8.4s as well The Governm8.1e-.9nt-6.9 however believes it need additional direction fr the Court before-5.5 producing a list of victim8.3s Th Governm8.5e-.5nt has advise the Court without supporting legal argum8.4ent or citation of authority th at disclosing the to petitioners counsel would violate state and federal law DE at The Governm8.4e-.6nt also inform8.7ed the Court that Case Document Entered on FLSD Docket Page of to u5.6nnecessa4.4ry litig5.6ation,5.6 it was a4.4ttem8.4p ting to de4.7term8.7ine whether any the individu5.7als will cons4.9ent to the4.5 disc4.5losure th and whether the petition5.8e-.4r3.8s0 are aware of or all of the DE at reason for alerting the Court to this developm8.5ent is that on July counsel for several sex abuse victim8.1s of Jeffrey Epstein filed a statem8.4ent that th ey did not want id6.4entities disclosed to petitioners counsel at this DE at In light of that statem7.7ent on July the Court entered a supplem8.3ental order indicati ng that the Government need not disclose the victim8.7s to petitione4.7rs cou5.9n.9sel un5.9til th Court has evaluated th Governm8.1e-5.9nt?s position that doing so would violate federa and state law DE at the4.9 the n6.1eed the4.9 overnm7.8e-1.2nt to draft a brie on th6.4is issue the petitioners to respond and for the C7.2ourt to rule petitioners counsel now7.8 notifies the Court that they are withdrawing their request further pr oduction of from th Governm8.4e-.6nt at this tim8.6e Petitioners now believ5.8e-.4 that their list of victim8.6s includes all those identif3.8i-1.4ed by the4.7 and then maki ng this debate unnecessary petitioners do not concede that disclosure of the would violate any unspecif8.6i-1.6ed federal state law fact it is e5sse5ntia5l tha5t-1 pe5tition6.2e0rs the each iden5.5tified victim for the purposes of a nd adequately prosecuting this acti on And should a future dispute or other circum8.7stance making a m8.7i-1.3ssing releva nt to these proceeding arise the petitioners W8.9ith regard to federal law court-ordered di sclosure of sex abuse victim8.1s to legal counsel occurs regularly for exam7.7pl-7.3e when the na is provided to defense counsel in a sex abuse case And with reg5.8a-.4rd to state law the Suprem8.3acy Clause U.S Const art VI would necessarily dictate th6.1at a federal co6.1urt orde requiring production would supers ede any conflictin5.5g.5 state law Petitioners counsel would reques that opportunity to provide a dditional briefing on these points should the C7.4ourt wish to rule on these issues Case Document Entered on FLSD Docket Page of reserv6.1e the right to requ6.1est for the to be form8.7ally provided by the Governm8.7e-.3nt But at th6is juncture it a4.8ppears th6at n6o1 further litigation on this point is required CONCL-4.1US-4.9ION light of Jane Doe No and Jane Doe No withdrawal of their request for the Governm8.3e-.7nt-6.7 to produce to their counsel the petitioners respectfully subm8.2it that the Court need not take any further action on this issue 2750DATED July Respectf4.3u1.3lly6.3 Subm9.1itted,6.3 Bradley Edwards Bradley E6.3d.5wards FARMER EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale Florida Telephone Facsim8.1ile brad6 pathtoju6s.2tice.com8.8 And Pro Hac Vice S.J 2750Quinney 2750College Salt 2750Lake 2750City Telephone Facsim8.2ile cassellp law.utah.edu 1250.5Attorneys for Jane Does No and The Court has also ordered that under no ci rcum8.5stances s4.9h.7all a victim8.5?s appear in nay court docum8.6ent unless filed u5.8nder DE at Petition5.8e-.4rs counsel are aware this an5.8d will of co5.8urse scrupulously abid5.4e by it This daytim7.5e business address is provided fo id6.4entif4.4ica5.2tion6.4 and co rrespondence purposes-6 only and is not intended5.8 to im8.6ply institu5.8tiona4.6l en5.8dorsem8.6e-.4nt by the Univer3.8sity Utah5.8 Case Document Entered on FLSD Docket Page of CERTIFICATE OF certif8.2y that the foregoing docum8ent was served on July on the following using the Court?s CM/ECF system8.3 and/or U.S Dexter Lee A Marie Villafa?a Australian Ave Suite West Palm8.2 Beach FL Fax Dexter.Lee usd5.7o.7j.gov ann.m8.3arie.c.villafana usdoj.gov Attorneys fo5.8r the Govern5.8m3ent And on Robert Josefsberg Podhurst Orseck P.a City Nation5.4a-.8l Bank Bld5.4g Flagler Street Suite Miam8.5i FL Attorney4.6s fo5.8r Settled Vic4.6tims5 Brad5.7ley Edwards Case Document Entered on FLSD Docket Page of
