Epstein Secrets

-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing before Your Honor on December 14, 2009 at 8

E FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XWMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Defen

in from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, EFTA00723281 B,B. v, Eosteiq Case No. 502008CA03 XMB AB Epstein's Objections to Request and Motion for Protective Order Page 10 of 22 videos, written statements, etc.) pert

P. 1.280(c), and states: I. Introduction 1. Mr. Epstein's deposition was set for September 2, 2009, and M

Motion to Compel as to certain requests to which Defendant Epstein was asserting a Fifth Amendment privilege. By th

P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA

efendant's computers in case involving disciplinary proceedings brought against teacher for exchanging sexually explicit emails with students); d. Goodyear Tire & Rubber Co. v. Cooey 359 So. 2d 1200 (Fla. 1st DCA 1978) (quashing order permitting inspection of tire plant because plaintiff did not demonstrate that tires m

ORDER OF THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA BRIEF OF INTERVENORS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebnick, Kornspan & Stumpf 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Tel: (305) 371-6421

n the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923 Date Filed: 08/05/2013

come of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923 Date Filed: 08/05/2013 Page: 3 of

RS/APPELLANTS ROY BLACK, MARTIN G. WEINBERG, AND JEFFREY EPSTEIN Roy Black Jackie Perczek Black, Srebni

ly pursued their civil monetary remedies against Mr. Epstein to completion — plaintiffs sought to use that co

& Health Plans, 16 F.Supp.2d 1164 (C.D.CaI. 1998) 33, 37, 40 Gill v. Gulfstream Park Racing Ass 'Ft, Inc., 399 F.3d 391 (1st Cir. 2005) 54 *Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 980 (6th Cir. 2003) 32,33, 38,40 Hickman v. Taylor, 329 U.S. 495 (1947) 14, 20, 21 Holt-Orsted v.

rs The second group consists of The Palm Beach Post and The Palm Beach Daily News. These entities moved for limited intervention in order to oppose Jeffrey Epstein's motion for protective order that sought to require sealing all pleadings that attached certain documents disclosed in discovery (DE305). The distr

enor Jeffrey Epstein be included and that, consistent with the Court's and Local Rule I 6.2(e)'s mandates that all the parties appear in person, Mr. Epstein be required to attend in person. PROCEDURAL HISTORY REGARDING INTERVENTION This action involves a petition filed on behalf of two individuals ("Ja

the United States requests that only intervenor Jeffrey Epstein be included and that, consistent with the

s mandates that all the parties appear in person, Mr. Epstein be required to attend in person. PROCEDURAL HIS

hapter." 18 U.S.C. § 3771(d)( I). 5 EFTA00211517 procedures, asserting a First Amendment right of access, and the courts denied such access. In Goodyear Tire & Rubber Co. I. Chiles Power Supply, Inc., 332 F.3d 976 (6th Cir. 2003), the Sixth Circuit went further, finding that settlement communications were privileged a

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. aLL, tl,g Goodyear Tire & Rubber Co. v. Chiles Power Stumlva Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to se

d therefore insulates the particular parties to a settlement discussion FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to ni t federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. Epstein p

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. See, e.g., Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to se

d therefore insulates the particular parties to a settlement discussion FRE 410(4) is particularly directed to communications in matters which, like Epstein's, did not result in a plea of guilty to ni t federal charge. Fla. Stat. §90.410 provides parallel protections in state criminal matters. Epstein p

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

of Rule 408 are covered by a settlement privilege which insulates them not just from admission into evidence but from discovery as well. See, e.g., Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc., 332 F.3d 976, 979-983 (6th Cir. 2003). Given the powerful and long-standing policy of according confidentiality to se

abaton Sucharow Latham & Watkins Law Offices of Jeffrey Delott Lipsitz & Ponterio Lowenstein Sandler M

tion Commission Citigroup Inc. Crum & Forster Holdings Corp. DuPont de Nemours Inc. Early Warning Services LLC Global Brands Group Holding Ltd. Goodyear Tire & Rubber Co. HDI Global Specialty SE Highgate Hotels Inc. Iconix Brand Group, Inc. KSL Capital Partners LLC Kenneth Cole Productions Inc. Kona Grill Inc. L