Epstein Secrets

LORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, 1. UNITED STATES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs' lawyers filed Pla

d allow Professor Dershowitz to intervene. At the very end, on page 38, the Plaintiffs quote from a 2007 plea and settlement negotiation letter that Epstein's defense lawyers sent to the government. The quote, in its entirety, is five or six words. The quote is redacted from the public filing but it is

Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein 17 EFTA00210733 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 18 of 18 CERTIFICATE OF SERVICE I HEREBY CERTIFY tha

TES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICA

ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, throug

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may rest

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

te 5 EFTA00606592 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 6 of 16 and what degree of protection is required." Seattle Times Co. v. Rhinehart, 467 U.S. 20, 35 (1984) (discussing Fed. R. Civ. P. 26(c)); see also F.T.C. v. AbbVie Prods. LW, 713 F.3d 54, 58 (11th Cir. 2013) (not

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

te 5 EFTA00674420 Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 6 of 16 and what degree of protection is required." Seattle Times Co. v. Rhinehart, 467 U.S. 20, 35 (1984) (discussing Fed. R. Civ. P. 26(c)); see also F.T.C. v. AbbVie Prods. LW, 713 F.3d 54, 58 (11th Cir. 2013) (not

LORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs' lawyers filed Pla

d allow Professor Dershowitz to intervene. At the very end, on page 38, the Plaintiffs quote from a 2007 plea and settlement negotiation letter that Epstein's defense lawyers sent to the government. The quote, in its entirety, is five or six words. The quote is redacted from the public filing but it is

TES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICA

ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, throug

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. v. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has "repeatedly acknowledged the private nature of discovery" and that "[a] court may re

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

out its contents." Tillman v. C.R. Bard, Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 2014 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the dissemination and use of pretrial discovery is particularly important since "[t]he

FLORIDA CASE NO. 08-80736-CIV-MARFtA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN=S RESPONSE To ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs= lawyers filed P

lawyers and parties in this case are already bound by a Protective Confidentiality Order issued by this Court on September 21, 2014, finding that AEpstein has shown good cause to prevent potential dissemination of the correspondence between the government and the intervenor to the press for the purpos

TATES OF AMERICA, Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN=S RESPONSE To ORDER REQUESTING JUSTIFICA

ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs= lawyers, Mr. Edwards, throug

could be damaging to reputation and privacy. The government clearly has a substantial interest in preventing this sort of abuse of its processes. Seattle Times Co. v. Rhinehard, 467 U.S. 20, 35 (1984). The Eleventh Circuit has Arepeatedly acknowledged the private nature of discovery@ and that A[a] court may re

Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 1 of 11 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON -------------~/ Related cases: 08-8

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

ROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

( emphasis added), common-law right of access does not extend to information collected through discovery which is not a matter of public record. See Seattle Times Co. v. Rhinehart, 467 U.S. 20, 33,104 S.Ct. 2199, 2207, 81 L.Ed.2d 17 (1984); Anderson, 799 F.2d at 1441; United States v. Gurney. 558 F.2d 1202, 1209

413 United States Court of Appeals for the Second Circuit Plaintlff-Appelke, —against— GHISLA1NE MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD MEDIA COMPANY, ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA Intervenors. ON APPEAL FROM TH

and sexual trafficking of minors. Her lawyers intended to prove the defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for Epstein. App. p 116, ¶ffil 8-10; p 119 9¶ 27; p 122, ¶ 12; p 123, 51114, 16; p 124,9120. 3 EFTA00075485 Case 20-2413, Document 40, 08/20/2020, 2913550, P

MAXWELL, Defendant-Appellant, SHARON CHURCHER, JEFFREY EPSTEIN, Respondents, JULIE BROWN, MIAMI HERALD

2 (2d Cir. 1994) Press-Enter. Co. a Superior Ct., 464 U.S. 501 (1984) S.E.C. v. TheStreet.Com, 273 F.3d 222 (2d Cir. 2001) passim 34 37 passim Seattle Times Co. v. Rhinehart, 467 U.S. 20 (1984) 24 State a Cady, 414 P.3d 974 (Utah Ct. App. 2018) 19 United States v. Amodeo, 44 F.3d 141 (2d Cir. 1995) ("Amod

he allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, U.S. Opens Inquiry Into Handling of Jeffrey Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usgbi-jeffrey-epstein.html. The exposi garnered attention from the med

hat Maxwell had defamed Giuffre by stating that Giuffre was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen

crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. 1.) B

scovery, and (3) does not restrict the dissemination of the information if gained from other sources," it is not improvidently granted. Id (quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 37 (1984)); see also FragranceNetcom, Inc. v. Fragrancel.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at •4 14 SDNY_GM_

t Ghislaine Maxwell, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post

ll, alleging that Maxwell had defamed by stating that was not the victim of sex crimes perpetrated by, among others, Maxwell and Jeffrey Epstein ("Epstein"). (15-cv- 7433, Dkt. No. I.) Boies Schiller represented the plaintiff in the litigation, and continues to represent her on a pending post-settlemen

the allegations against Epstein and suggesting that the plea deal constituted Government misconduct. Liam Stack, US. Opens Inquiry Into Handling of Jeffrey? Epstein's Sex Abuse Case, N.Y. Times (Feb. 6, 2019), https://www.nytimes.com/2019/02/06/usfibi-jeffrey-epstein.html. The expose garnered attention

scovery, and (3) does not restrict the dissemination of the information if gained from other sources," it is not improvidently granted. Id (quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 37 (1984)); see also FragranceNetcom, Inc. v. FragranceX.com, Inc., No. 06-cv-2225, 2010 WL 11606632, at *4 14 CONFIDEN