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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
f protecting the various privileges, and to respond to the personal attacks made upon them individually by Rosenbaum." [DE 125, p. Garfinkel and Katzman will be permitted to inter- vene for the former purpose, but not the latter•. According to the Motion to Intervene, Rosenbaum served as counsel fo
ility to manage its proceed- ings, vindicate its authority, and effectuate its decrees without extending its jurisdic- tion. Keith Jeffrey Lambdin, Katzman Gar- finkel Rosenbaum, John David Mallah, Maitland, FL, for Plaintiff. Bradley Ryan Weiss, Benson Mucci & Associates LLP, Thomas E. Tookey, Coral
eving that Bill Clinton was on the airplane with Mr. Epstein and these young woman ..." (18:24-19:4.) • "I c
/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant, Jeffrey Epstein ("Epstein"), moves' this Court for an in camera inspection of
liver the accompanying sealed Memorandum by November 9, 2018. Edwards was instructed to deliver a response sealed Memorandum by November 16, 2018. 2Epstein has reduced the original 47 e-mails for in camera review down to 30 e-mails. 3Farmer Jaffe agreed to produce all work-product related to closed case
OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT
must be rejected in favor of the truth. See Loureiro v. State, 133 So. 3d 948, 956 (Fla. 4th DCA 2013)("A trial must be a search for the truth."); Katzman v. Rediron Fabrication, Inc., 76 So. 3d 1060, 1063 (Fla. 48' DCA 2011)("...jury can the search for truth and justice be accomplished"). Not only ar
August 19, 2019 Date: Mon, 19 Aug 2019 21:17:23 +0000 Attachments: 2019 8-19.pdf According to WSJ, there were two prosecutors in DANY who handled Epstein's effort to get reduced sex offender level: Jennifer Gaffney and Pat Egan. Documents Show Efforts by Jeffrey Epstein's Attorneys to Sway Prosecutor
re two prosecutors in DANY who handled Epstein's effort to get reduced sex offender level: Jennifer Gaffney and Pat Egan. Documents Show Efforts by Jeffrey Epstein's Attorneys to Sway Prosecutors WSJ By Joe Palazzolo 8/18/19 Local prosecutors in Manhattan labeled Jeffrey Epstein a low-level sex offender nearly
hat Epstein's only potential heir was his brother, Mark Epstein. But the will adds that Mark only had a claim to his brother's extensive holdings if Jeffrey hadn't left behind the document. Jeffrey Epstein had been sued by a multitude of sex accusers before his death, and the lawsuits are still piling o
that Jordan would bring to his new position. EFTA00077533 "We are fortunate to have Michael Jordan with us in his new role as circuit executive," Katzman said. "We know he will continue to serve the federal judiciary and the public with distinction." Under federal statute, the circuit executive overs
2019 5:17 PM To: (USANYS) < Subject: FW: SDNY News Clips Monday, August 19, 2019 According to WSJ, there were two prosecutors in DANY who handled Epstein's effort to get reduced sex offender level: Jennifer Gaffney and Pat Egan. Documents Show Efforts by Jeffrey Epstein's Attorneys to Sway Prosecutor
re two prosecutors in DANY who handled Epstein's effort to get reduced sex offender level: Jennifer Gaffney and Pat Egan. Documents Show Efforts by Jeffrey Epstein's Attorneys to Sway Prosecutors WSJ By Joe Palazzolo 8/18/19 Local prosecutors in Manhattan labeled Jeffrey Epstein a low-level sex offender nearly
hat Epstein's only potential heir was his brother, Mark Epstein. But the will adds that Mark only had a claim to his brother's extensive holdings if Jeffrey hadn't left behind the document. Jeffrey Epstein had been sued by a multitude of sex accusers before his death, and the lawsuits are still piling o
igh standards" that Jordan would bring to his new position. "We are fortunate to have Michael Jordan with us in his new role as circuit executive," Katzman said. "We know he will continue to serve the federal judiciary and the public with distinction." Under federal statute, the circuit executive overs
l identified as Minor Victim-1 to travel from Florida to New York "with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55." Id. ¶ 13. Count Three alleges that Ms. Maxwell conspired to transport "an individual" in inte
would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130
Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &
ed that the legislative history at issue did not clearly evidence Congress' intent regarding retroactivity. Id. That is not the case here. As Judge Katzman of the Second Circuit has recognized, unambiguous legislative history should not be disregarded: When courts construe statutes in ways that respect
Entities connected to both Jeffrey Epstein and Katzman

Richard Kahn
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Marc Rich
PERSONDarren Indyke
PERSONLeon Black
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Prince Andrew
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Ghislaine Maxwell
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Boris Nikolic
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Woody Allen
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John F. Kennedy
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Eric Trump
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George Mitchell
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George W. Bush
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Donald Trump
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Bradley Edwards
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United States
LOCATION
Jes Staley
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Stephen Hawking
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Joe Biden
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Prince Charles
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Michael Cohen
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