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

ounsel for the plaintiff to prepare a number of witnesses, including management officials of plaintiff, for their depositions. The District Court, Grimm, United States Magistrate Judge, held that: (1) documents supplied by plaintiffs coun- sel to prepare two management officials for deposition were

lse and misleading statements about its anti-money laundering policies and failed to monitor `high-risk' customers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.97M) reports, "The investigation is being led by the FBI, which declined to comment. The New Jersey State P

stomers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.97M) rep

risk' customers including convicted sex offender Jeffrey Epstein." ABC News (7/19, Margolin, Katersky, 2.

th since the Supreme Court blocked the Trump administration's attempt to end the Deferred Action for Childhood Arrivals program." According to CNN, Grimm "said...that the program is to be restored to its `pre-September 5, 2017 status,' meaning the status quo before President Donald Trump tried to ter

01-2, 309 of 2017, 301-2 of 2018, 171, 309-10 of 2020, 308-9 HOUSE_OVERSIGHT_020125 Emanuel, Rahm, 27 Enron, 278 environmental regulation, 182, 295 Epstein, Edward Jay, 102 Epstein, Jeffrey, 28 Europe, 5, 142 European Union, 99 executive orders (EOs), 120, 133 climate change, 182 immigration and travel

171, 309-10 of 2020, 308-9 HOUSE_OVERSIGHT_020125 Emanuel, Rahm, 27 Enron, 278 environmental regulation, 182, 295 Epstein, Edward Jay, 102 Epstein, Jeffrey, 28 Europe, 5, 142 European Union, 99 executive orders (EOs), 120, 133 climate change, 182 immigration and travel ban, 61-65, 68, 70, 78, 95, 113,

143-49, 174, 179, 184, 270, 305 Goldman Sachs Foundation, 82 Goldwater, Barry, 127 Gore, Al, 123 Gorka, Sebastian, 129 Gorsuch, Neil, 85-87, 133 Grimm, Michael, 310 Guardian, 276 Guilfoyle, Kimberly, 223, 272-73, 284 H-1B visas, 36 Haberman, Maggie, 91-92, 206-7, 277 Hagin, Joe, 186, 229 Hahn, J

ation submitted to the University of California at Los Angeles. Dr. W. E. Jeffrey, Chairperson. X. PUBLICATIONS Greitzer (aka, Goodman), G. S., Si Jeffrey, W. E. (1973). Negative effects of the pretest in training conservation of length. Developmental Psychology, 9, 435. Goodman, G. S. (1980). Picture

J., & Eisen, M. L (in press). Memory accuracy for interviews about childhood trauma after 20 years. Child Maltreatment. Cordon, I. M., Chong, J., Grimm, K., Chong, J. Y., Christo, C., Mendoza, M., Clinton, A., & Goodman, G. S. (submitted). Identifying learning disabilities screens for Spanish-speaki