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trict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case °fin re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied relief under the Crime Victims' Restitution Act before any ch
d by the government arc subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe I and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe 1 and Jane Doe 2 EFTA00177187 Case 9:08-cv-80736-KAM Document 56 Entered on
. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant. NOTICE OF' OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epstein du
AM Document 56 Entered on FLSD Docket 04/07/2011 Page 2 of 19 Non-Prosecution Agreement reached between the U.S. Attorney's Office and Mr. Epstein. Jane Doe 1 and Jane Doc 2 also seek other unspecified relief, which they call "appropriate remedies," for the government's purported failure to keep them invol
rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. hid. Dec. 8,2010), the district court denied relief under the Crime Victims' Rights Act before any charges
161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LE
trict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case ofln re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (RD. Ind. Dec. 8, 2010), the district court denied relief under the Crime Victims' Restitution Act before any cha
d by the government are subject to a protective order prohibiting their disclosure. In the related case 9:08-CV-80893 (the case where Jane Doe 1 and Jane Doe 2 sued Mr. Epstein for money), the Magistrate Judge prohibited Jane Doe I and Jane Doe 2 EFTA00205542 Case 9:08-cv-80736-KAM Document 160 Entered on
ges. It was at that point (at a minimum) that the Government should have extended to the victims their right to confer. To the same effect is In re Peterson, 2010 WL 5108692 (N.D. Ind. 2010), a case that the Government cites as supporting its position. Gov't Resp. at 21-22. But Peterson squarely rejects
ecute the specific offenses that were committed against these victims. The Government violated the rights that the CVRA extended to Jane Doe #1 and Jane Doe #2. The Government did not afford the victims their right to confer about the non- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — a
ssing the concept in the context of the attorney-client privilege); Baratta v. Homeland Housewares, LLC, 242 F.R.D. 641, 643 (S.D.F1a.2007) (same); Peterson v. Wallace Computer Servs., Inc., 984 F.Supp. 821 (D.Vt.1997) (same). And all other privileges and protections can similarly be waived. II. The Go
Document 414 Entered on FLSD Docket 08/11/2017 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-cv-80736-KAM JANE DOE 1 AND JANE DOE 2, Petitioners, v. UNITED STATES, Respondent. JANE DOE 1 AND JANE DOE 2'S MOTION FOR FINDING OF WAIVER OF WORK PRODUCT AND SIMILAR
rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (M. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The court
ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negotiations as substantive evidence in their quest to inva
rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The cour
Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the
rict court had no authority under mandatory restitution act to reopen restitution proceedings after sentencing). More recently in the case of In re Peterson, No. 2:10-CV-298, 2010 WL 5108692 (M. Ind. Dec. 8, 2010), the district court denied relief under the CVRA before any charges were filed. The court
ls between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Prosecution Agreement [DE 51], as well as their motion t
ges. It was at that point (at a minimum) that the Government should have extended to the victims their right to confer. To the same effect is In re Peterson, 2010 WL 5108692 (N.D. Ind. 2010), a case that the Government cites as supporting its position. Gov't Resp. at 21-22. But Peterson squarely rejects
o intervene at this time because the issue of whether the Crime Victims' Right Act even applies in this case is a matter between the government and Jane Doe 1 and Jane Doe 2 . . . ." Mot. at 5. By conceding this point on behalf of Jeffrey Epstein, the defense attorneys have conceded that Epstein knows th
D.M. & Loftus, E.F. (2009) The consequences of false memories for food preferences and choices. Perspectives on Psychological Science, 4, 135-139. Peterson, T., Kaasa, S.,O. & Loftus, E.F. (2009). Me too! : Social Modeling Influences on Early Autobiographical Memories. Applied Cognitive Psychology. 23,
Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu
Entities connected to both Peterson and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Alan Dershowitz
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Salt Lake City
LOCATIONSouthern District
LOCATION
Alexander Acosta
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Prince Andrew
PERSON