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mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal 'Whether or not the CV RA applies is the central question in dispute in this matter because no federal criminal case
0736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 3 of 9 plea proceedings. Id., citing United States,. Ingrassia, 2005 WL 2875220 at •17 (E.D.N.Y. Sep. 7, 2005). The district court concluded, "[t]he CVRA, therefore, dots not authorize an unbridled gallop to any and all information in the gover
ane Doc 2 to release materials that are plainly the privileged opinion work-product of the attorneys, that constitute settlement negotiations under Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure II, and that contain information about matters occurring before the grand jury, which arc strictly confidenti
Bureau of Investigation began investigating allegations that Jeffrey Epstein had sexually abused several minor girls. The United States Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane
rs argued that the work-product privilege 5 EFTA00209389 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury
Bureau of Investigation began investigating allegations that Jeffrey Epstein had sexually abused several minor girls. The United States Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane
rs argued that the work-product privilege 5 EFTA00209430 Case: 13-12923 Date Reed H4118/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury
Bureau of Investigation began investigating allegations that Jeffrey Epstein had sexually abused several minor girls. The United States Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane
argued that the work-product privilege 5 EFTA00209636 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury
Bureau of Investigation began investigating allegations that Jeffrey Epstein had sexually abused several minor girls. The United States Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane
argued that the work-product privilege 5 EFTA00209745 Case: 13-12923 Date Filed: 04/18/2014 Page: 6 of 23 protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jury
Bureau of Investigation began investigating allegations that Jeffrey Epstein had sexually abused several minor girls. The United States Attorney's Office for the Southern District of Florida accepted Epstein's case for prosecution, and the Federal Bureau of Investigation issued victim notification letters to two minors, Jane
P. 24(b), the intervenors moved for protective orders. The intervenors argued that the work-product priv- ilege protects their correspondence; that Federal Rule of Evidence 410 and Feder- al Rule of Criminal Procedure 11 create a privilege for plea negotiations; and that their correspondence contained confidential grand jur
bject to use of the documents there: "Epstein is not a party to that suit, which involves Jane Does #1 and #2's allegations that the U.S. Attorney's Office for the Southern District of Florida violated their rights. Accordingly, without intervening in the case, he cannot raise any objections to the use of the correspondence in
against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this
bject to use of the documents there: "Epstein is not a party to that suit, which involves Jane Does #1 and #2's allegations that the U.S. Attorney's Office for the Southern District of Florida violated their rights. Accordingly, without intervening in the case, he cannot raise any objections to the use of the correspondence in
against him because of Rule 410 of the Federal Rules of Evidence. See Exhibit A to Epstein's Mot. to Intervene, DE #93-1 (arguing that pursuant to Federal Rule of Evidence 410, Epstein is entitled to some sort of protective order). If this pleading has a familiar ring to it, it is because Epstein has presented it to this
e FBI began investigating allegations that wealthy investor Jeffrey Epstein had sexually abused dozens and dozens of minor girls. The U.S. Attorney’s Office for the Southern District of Florida accepted Epstein’s case for prosecution, and the FBI] issued victim notification letters to my two clients, minors Jane Doe No. | and Jane
r discovery of the correspondence between the U.S. and Epstein’s attorneys during the plea negotiations. Epstein’s attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations, barring release of the correspondence. They also argued that the
Entities connected to both Southern District of New York and Federal Rule of Evidence 410

Jeffrey Epstein
PERSONthe Southern District
LOCATION
United States
LOCATION
Department of Justice
ORGANIZATIONFBI
ORGANIZATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Prince Andrew
PERSONJack Goldberger
PERSON
George W. Bush
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONMartin Weinberg
PERSON
Michael Cohen
PERSON