Epstein Secrets

tiff's MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the US. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe & filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 85 Notice of Supplemental Authority re 48 Plaintiff's MOTION for

ed: 03/29/2012) 04/17/2012 L62 MOTION for Protective Order by Intervenors Black Weinberg and LeJkowitz and Opposition to Motions of Jane Doe I and Jane Doe 2 For Production, Use, and Disclosure of Settlement Negotiations by Roy Black. (Perczek, Jacqueline) (Entered: 04/17/2012) 04/17/2012 161 MOTION fo

eth A. Marra on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 100 RESPONSE/REPLY to 94 Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lefkowitz by United States of America. ( Ann Marie) (Entered: 09/27/2011) 09/28/2011 i (Court only) ***Motions terminated: 41 Plaintiffs MO

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. / REPLY IN SUPPORT OF MOTION TO INTERVENE OF ROY BLACK, MARTIN WEINBERG, A

pose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was already turned over to them. They are mistaken. Undersigned counsel spoke with Pa

ENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ Jane Doe I and Jane Doe 2 oppose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was alread

ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou

ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum

ed by Judge on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 jail RESPONSE/REPLY tom Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lelkowitz by United States of America. (Villafana, Ann Marie) (Entered: 09/27/2011) 09/28/2011 jaL MOTION for Extension of Time to File Respo

ea negotiation letters and emails. The plaintiffs are mistaken. First, collateral estoppel requires identity of parties and no such identity exists. Jane Doe 1 and Jane Doe 2 in this CVRA case were not parties to the federal damages case from which the Magistrate Judge's order originated, and neither were t

RICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only

n FLSD Docket 06/06/2012 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a motion by limited intervenors

TES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefkowitz, to strike the plaintiffs' notice of supplemental authority [DE 173] because the "authority" cited by the plaintiffs — a comment by

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56), as well as during the August 12, 2011 hearing.

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing.