3
Shared Docs
3
Same-Page
12 / 3
Mentions
uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
, both their opponent's version of the matters in dispute and a neutral assessment of the relative strengths of the opposing positions." Sheldon v. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, 513 (W.D. Pa. 2000). In other words, the parties are allowed to disclose documents and information normally covered by the att
uring those negotiations against either party. BACKGROUND The Court is very familiar with this matter, having handled the civil suits filed against Jeffrey Epstein pursuant to the Non-Prosecution Agreement and this actions filed by Jane Does #1 and #2 against the United States. For purposes of this Supplemental
of the government, the Jane Does have only received the portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Ja
gotiations between the Intervenors (on behalf of Jeffrey Epstein) and the U.S. Attorney's Office. The Inte
by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by
, both their opponent's version of the matters in dispute and a neutral assessment of the relative strengths of the opposing positions." Sheldon v. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, 513 (W.D. Pa. 2000). In other words, the parties are allowed to disclose documents and information normally covered by the att
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
ct that many federal district courts rely on the success of ADR proceedings to minimize the size of their dockets." Id. More recently in Sheldonel. Pennsylvania Turnpike Comm'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000), the court relied on Jaffee and on Judge Marcus' decision in In re Air Crash Near Cali, Colombia to hold that
Entities connected to both Jeffrey Epstein and Pennsylvania Turnpike Comm'n
Leon Black
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONSouthern District
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONRoy Black
PERSON
Salt Lake City
LOCATION
Supreme Court
ORGANIZATION
Robert Mueller
PERSON
Philippines
LOCATIONSecond Circuit
ORGANIZATION
the University of Utah
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION