Epstein Secrets

F FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, EXHIBIT A UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE I AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Purs

DATORY AND DISCRETIONARY INTERVENTION An PROPER Intervention is proper as a matter of right under Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and confidential plea negotiations, and "disposing of the action may as a practical matter impair or im

rees without extending its jurisdic- tion. Keith Jeffrey Lambdin, Katzman Gar- finkel Rosenbaum, John Davi

er Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and

deral law claims in a case also presenting state law claims, the fed- eral rule favoring admissibility ...I the controlling rule."); von Bulow von Bulow, 811 F.2d 136, 141 ( d Cir.I987) (holding that federal law controlled question of privilege where federal civil RICO claims were joined with s

To: Peggy Siega From: Jeffrey Epstein Sent Thur 12/29/2011 10:07:33 AM Subject Re: Palm Beach it is a good reminder , of why you left On Thu, Dec 29, 2011 at 3:41 AM, Peggy Siegal <

To: Peggy Siega From: Jeffrey Epstein Sent Thur 12/29/2011 10:07:33 AM Subject Re: P

To: Peggy Siega From: Jeffrey Epstein Sent Thur 12/29/2011 10:07:33 AM Subje

igner wife in North Palm...they bought a wreck and fixed it up and have rented it next week for 3 months to Ala Isham's brother. They are Sunny von Bulow's grown kids. I think I will stay close to David's house till Jan. 2nd. I am on a 9:00am flight that Monday and will go directly to the Alpine hous

York, NY 10007 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca Denver. Colorado 80203 Re: Response t

im Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Seven (7) photocopied pages of this journal, two of which are the front and back covers, were selectively produced by BSF in discovery during civil

vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac

to protect the adverse "party, the factfinder, and the judicial process from selectively disclosed and potentially misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Ci