Epstein Secrets

is time because the issue of whether the Victim Victims' Rights Act even applies in this case is a matter between the government and Jane Doe I and Jane Doe 2 . . . To the extent the Court were to consider invalidating the Non-Prosecution Agreement as a remedy, Jeffrey Epstein reserves the right to interv

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

intervene at this time because the issue of whether the Victim Victims' Rights Act even applies in this case is a matter between the government and Jane Doe 1 and Jane Doe 2 . . . . To the extent the Court were to consider invalidating the Non-Prosecution Agreement as a remedy, Jeffrey Epstein reserves the

required to make the same initial disclosures that are part and parcel of civil suits. He would also presumably be subject to deposition. See Fox v. Tyson Foods, Inc., 519 F.3d 1298, 1305 (11th Cir. 2008) (affirming denial of motion to intervene because of delay that would be involved in deposing the intervenors)

er & Flexner LLP took on Ms. Roberts' representation because she was a victim of abuse when she was a minor child." David Boies Is Now Representing Jane Doe #3 (Apr. 26, 2015), http:/hhecareerist.typepad.comithecareerist/ 2016/04/alan•dershowitz•on-the-record.html (last viewed May 9, 2016). 5 EFTA00618

ions of the agreement were prepared in anticipation of litigation and therefore fall within the definition of attorney work product."); Oklahoma v. Tyson Foods, Inc., No. 05-CV-329, 2007 WL 3128422, at • (N.D. Okla. Oct. 24, 2007). 10 EFTA00618143 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 13 of 1

led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (

t her entire amended complaint, the plaintiff uses the term "scheme" as though it were a password for gaining access to RICO standing. Cf. Newton'. Tyson Foods, Inc., 207 F.3d 444, 447 (8th Cir. 2000) (observing in the context of indirect and attenuated RICO allegations that "[t]he mere recitation of the chain o