Epstein Secrets

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tell the girls." U.S. Attorneys Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epsteinls-tiefense-eounsel-was-that-ne-mention-weuld-be-made-octhe-ROli-pfeseeutiewegreement between-the-U,SrAttertieyls-Gfflee-anii-Epsteiur as-fie-subseque

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of Crime Victims' Rights in Registered Pedophile Jeffrey E Epstein Case Posted on Wed, Apr 23,2014 1.1.1/4

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o settle civil suits BY SUSAN SPENCER.WENDEL Pam 80•01 Post Shoff Meer Friday. Seplamber 10.2009 WEST PALM BEACH — fiflonaire Mender sex offender Jeffrey Epstaln's secret non-proseaNch weaned ha 'Ouch with Wein prosecutor, was Waxed Friday. Offering the not pubic look et the deal Epstein's high-powered legal c

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his client

2006 the FBI began investigating allegations that Jeffrey E. Epstein had sexually abused dozens and dozens of

ter-about-the-money isuo, just about what crimes Mr. Epstein is pleading guilty to and the amount of time-tha

ture of discovery" Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process because the litigants and the court

vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING INTERVENOR'S MOTION FOR A PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Protective Order. (DE 261). The once-unopposed motion is now opposed by Petitioners (DE 298) and prospective in

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors h

DER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Pr

he plea and non-prosecution negotiations between Mr. Epstein's counsel and the government." (Id. at 9). The C

order, arguing that "case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Espstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe 1 and Jane Doe 2 already have remain c

apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard

vs. UNITED STATES OF AMERICA, Respondent. ORDER DENYING INTERVENOR'S MOTION FOR A PROTECTIVE ORDER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Protective Order. (DE 261). The once-unopposed motion is now opposed by Petitioners (DE 298) and prospective in

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors h

DER This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a Supplemental Pr

he plea and non-prosecution negotiations between Mr. Epstein's counsel and the government." (Id. at 9). The C

order, arguing that "case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Espstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe 1 and Jane Doe 2 already have remain c

apply the correct legal standard and follow the proper procedures in determining whether a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 263 F.3d 1304, 1309 (I I th Cir. 2001). A. Legal Standard Intervenor Epstein argues that the proper legal standard is the "good cause" standard

1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-804

y intention of disclosing the information about her abortions to her parents. Jane Doe No. 4 is presently 22 years old. 4. Counsel for Defendant Epstein asked Jane Doe No. 4 a number of questions at her deposition indicating clearly that Jane Doe No. 4’s abortions would be a subject of inquiry in her

o. 4 is presently 22 years old. 4. Counsel for Defendant Epstein asked Jane Doe No. 4 a number of questions at her

d states as follows: 2. Counsel for Defendant Jeffrey Epstein have advised Plaintiffs’ counsel that the

t the other person’s interest in seeking the discovery.” Harrison v. Burlage, 2009 WL 2230794 at 4 (S.D. Fla. 2009) (citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc. 7. Plaintiffs great concern is that through leading questions Defendant’s counsel will inform Jane Doe No. 4’s parents about the abortions. Epstei

es’ 2-7 Motion for Protective Order and Incorporated Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8’s Motion for Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Ex. A); Jane Doe No. 4’s M

es Plaintiff Jane Doe No. 4’s Motion for Protective Order, pursuant to S.D.Fla.L.R. 7.1, and states as follows: 1. On April 19, 2010, Defendant Epstein’s counsel advised Plaintiff’s counsel that he was setting dates for additional depositions related to Jane Doe No. 4. The persons to be subpoenaed

and states as follows: 1. On April 19, 2010, Defendant Epstein’s counsel advised Plaintiff’s counsel that he wa

Doe Nos. 2-8’s Motion for Protective Order as to Jeffrey Epstein’s Attendance at Deposition of Plaintiffs,

st the other person’s interest in seeking the discovery.” Harrison v. Burlage, 2009 WL 2230794 * 4 (S.D. Fla. 2009) (citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304 (11th Cir. 2001)). 9. The persons sought to be deposed would not have information probative of Jane Doe No. 4’s claims or Defend

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend

the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'

ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea

the asserted right of access against the other party's interest in keeping the information confidentiarRomero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11* Cir. 2001). In balancing the competing interests, the court appropriately considers "whether allowing access would impair

LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of the Federal R

ernment in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and ser

rvenors. INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER AND INCORPORATED MEMORANDUM OF LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court for the entry a Protective Confid

ROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and served a prison sentence and a term of community control probation. The agreement, with which he has f

e of discovery" Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11t' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process because the litigants and the courts

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

er Rule 6(eX3)(AXii) or (iii). 2 EFTA00600055 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

asserted right of access against the other party's interest in keeping the information confidential." Romero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11' Cir. 2001). In balancing the competing interests, the court appropriately considers "whether allowing access would impair

ting the Summary Judgment Motion (hereinafter "Motion") filed by the Petitioners in the CVRA case, 08-cv-80736-KAM, Dkt. 361. Dear Mr. Although Mr. Epstein is a limited intervenor rather than a party to the CVRA case between the Government and the Jane Does, please find several rebuttal arguments to the

se, 08-cv-80736-KAM, Dkt. 361. Dear Mr. Although Mr. Epstein is a limited intervenor rather than a party to th

, 180 (1st Cir. 2003)(Both the constitutional and the common law rights of access have applied only to judicial documents"); Chicago tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1311 (11th Cir. 2001) ("when applying the common law right of access federal courts traditionally distinguish between those items w