Epstein Secrets

207 Entered on FLSD Docket 07/08/2013 Page 1 of 11 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 MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT THE REMEDY

made by the victims to seek a remedy that would harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an

harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et at, Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo

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 MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT THE REMEDY

made by the victims to seek a remedy that would harm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an

arm him," Motion to Dismiss Non-Party Interlocutory Appeal (filed by plaintiffs in Jane Doe #1 and Jane Doe #2 v. United States, Roy Black, et al., Intervenors, Eleventh Circuit No. 13-12923, citing Doc.108 at 13 n.3 (Mr. Epstein's assertion that he has an interest in the non-prosecution agreement which wo

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

ce in its entirety is probative of the issues which will be raised in the Motion to Dismiss, including whether the statute of limitations has run on Jane Doe's claim, whether the Court in the Jane Doe Matter has personal jurisdiction over the defendants, and whether the Motion to Dismiss should be granted

of the issues the Intervenors intend to raise in the Motion to Dismiss. To use the Jane Doe Evidence to support the Motion to Dismiss, however, the Intervenors need relief from the Protective Order. Judge Koeltl instructed the Intervenors to "make their application for relief from the Protective Order to th

re: ROTI ISTEIN ROSENFELD ADLER. PA. Debtor(s). Case No. 09-34791-BKC-RBR Chapter 11 ORDER DENYING MOTION TO STRIKE INTERVENORS L.M., E.W., AND JANE DOE'S LIST OF REQUESTED RELIEF OR, IN THE ALTERNATIVE, TO CONDUCT LIMITED DEPOSITION DISCOVERY [D.E. 63931 THIS MATTER came before the Court for a heari

Motion [D.E. 6393]. The Order to Show Cause directed the Intervenors to file a summary of damages, but the Order to Show Cause did not prohibit the Intervenors from filing additional pleadings, such as a List of Requested Relief. [D.E. 6366]. Intervenors remain required to file a summary damages, and the Co

MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstein ("Epstein") replies to the Intervenors, IM and Jane Doe's Response (D.E. 6446) to Epstein's Motion to Take the Intervenors' Depositions and to Compel their Mental Examinations (Epstein's "Motion") (D.E. 64

the Intervenors' Depositions and to Compel their Mental Examinations (Epstein's "Motion") (D.E. 6440), and states: INTRODUCTION Inexplicably, the Intervenors' counsel insists on making the Intervenors relive (and attempt to re-litigate) their settled sexual abuse claims against Jeffrey Epstein. Although t

obtained from the U.S. Attorney's Office or the U.S. Department of Justice. Rather, they were obtained from counsel for Jeffrey Epstein pursuant to Jane Doe # 1 's civil suit against Mr. Epstein, to which the United States was not a party. Thus, the United States has never had the opportunity to litigat

d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the

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, ROY BLACK, et al., Intervenors. INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY

d on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E

EXHIBIT 1 EFTA00605701 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plantiffs, v. UNITED STATES OF AMERICA, Defendant, ROY BLACK, el at, Intervenors / PROPOSED ORDER OF CONFIDENTIALITY ("PROTECTIVE ORDER"

n paragraph 5.a. above, upon prior written consent of the Producing Party's and Intervenors' counsel. If either the Producing Party's counsel or the Intervenors' counsel refuses to give consent, the CDM shall not be disclosed. The Receiving Parties may apply to the Court for an order of relief, on notice to

MEDIATION CONFIDEN ER TI-IIS CAUSE came before the Court upon th t of (1) Bradley J. Edwards ("Edwards"), (2) Jeffrey Epstein ("Epstein"), nors Jane Doe, M t and= (collectively, "Intervenors"), and (4) F' eissing Edwards Fistos and Lehrman ("Farmer Jaffe") (collectively, the "Me cipants"), to part

ds, Epstein and a repr m Farmer Jaffe who has the full authority to settle without further consultation shall app at the mediation in person. The Intervenors' counsel, who shall have full authority to settle the matter without further consultation, shall appear at the mediation by telephone. FILED: PALM