Epstein Secrets

e reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p

entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described

onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma

ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe

e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

airline pilots who report incidents and violations, In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); the decision of Judge Vinson, now the Chief Judge in the Northern District of Florida, denying discovery and recognizing a privilege for a corporation that reports contaminatio

intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use, and disclosure of his plea

ntervene. Established case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Epstein'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

morandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective

disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the gove

te ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reiclzhold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district co

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. 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 Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negot

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

ate ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 MI. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichold Chemicals, Inc. v. Textron, Inc., 157 . 522 (M. Fla. 1994); and by a number of district courts rec

Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non-Pr

Intervenor Jeffrey Epstein s Motion For a Protective Order And Oppo

during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

e ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichold Chemicals, Inc. v. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district cour

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1 AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Pr

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

vate ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (M. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichold Chemicals, Inc. v. Textron, Inc., 157 =. 522 EFTA00301882 (M. Fla. 1994); and by a number of dis

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

te ends, have been recognized by Judge Marcus in the case of In Re Air Crash Near Cali, Colombia, 959 F. Supp. 1529 (S.D. Fla. 1997); by Chief Judge Vinson of the Northern District of Florida in Reichhold Chemicals, Inc.. Textron, Inc., 157 F.R.D. 522 (N.D. Fla. 1994); and by a number of district court

o: (NY) (FBI); I. (NY) (FBI); (NY) (FBI) Subject: Re: Epstein Arrest / Search Warrant Stand-By List We just received the silent notification for Epstein's flight manifest and he will be landing at Teterboro airport tomorrow (7/6/19) at 5:20 PM. More details to follow but assume we will be meeting at

week, at the following cell phone numbers: Background for U.S. v. Epstein approaches: Arrest facts we can convey to individuals being approached: Jeffrey Epstein has been arrested and charged with sex trafficking of minor girls and conspiring with others to traffic minor girls for paid sex acts. He has been c

s we can convey to individuals being approached: Jeffrey Epstein has been arrested and charged with sex tr

nks, From: Gang, William J. II (CE) (FBI) Sent: Friday, July 5, 2019 4:12:46 PM To: =I (NY) (FBI) Cc: Kaplan, Jason A. (CE) (FBI); (CE) (FBI); Vinson, Eugene J. (CE) (FBI) Subject: RE: Epstein Arrest / Search Warrant Stand-By List Be advised, the Hendersonville address provided appears to belong

nt COVID-19 Vaccine Distribution. • Continuing Coverage: FBI Traced Ghislaine Maxwell Using Cell Phone Data. • Continuing Coverage: Barr Questioned Jeffrey Epstein's Cellmate. EFTA00148578 • Undercover Police Sought To Buy A Gun From Dolal Idd Prior To Fatal Shooting. • Man Held On Bail For Attempted Arson Of

. • Continuing Coverage: Barr Questioned Jeffrey Epstein's Cellmate. EFTA00148578 • Undercover Police S

one Data. • Continuing Coverage: Barr Questioned Jeffrey Epstein's Cellmate. EFTA00148578 • Undercover

igns. The AP (1/5, Barakat) reports G. Zachary Terwilliger, US Attorney for the Eastern District of Virginia, announced he is resigning to join the Vinson and Elkins law firm. The Richmond (VA) Times-Dispatch (1/5, Green, 401K) reports, "With President-elect Joe Biden taking office later this month, T

& Plimpton Duval & Stachenfeld Eagan Avenatti Epstein Becker Green Eversheds Sutherland Freshfields B

TE & DEVELOPMENT NYC Real Estate Week In Review Jeffrey Zwick, Keusch Law and Ballard Spahr were among mo

the Southern District of New York U.S. District Court for the Western District of New York U.S. Supreme Court EFTA00018863 --- PAGE BREAK --- Vinson & Elkins Atty Tapped For Texas High Court A seat on the Texas Supreme Court that will soon be vacated by a justice who has been confirmed to the fe

s Polk Dentons Dickinson Wright Dudley Topper Epstein Becker Green EFTA00032976 --- PAGE BREAK ---

Heller Seward & Kissel Seyfarth Shaw Sheppard Mullin Skadden Susman Godfrey The Gardner Firm PC The Jaffe Law Firm Togut Segal Venable LLP Vinson & Elkins Willkie Farr Yarborough Applegate EFTA00032977 --- PAGE BREAK --- companies of colluding to fix prices on crowns, numbing agents, X-ra