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

Motion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation'. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Rep

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

on Picture Incl. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldone v. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation v. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Re

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

te 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 attorney work product privilege without fea

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

te 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 attorney work product privilege without fea

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

tion Picture Ind. Pension & Health Plans, 16 F. Supp. 2d 1164, 1173 (C.D.Ca. 1998); Sheldon I. Pennsylvania Turnpike Comm 'n, 104 F. Supp. 2d 511, (W.D. Pa. 2000); Microsoft Corporation. Suncrest Enterprise, 2006 WL 929257 (N.D. Cal. Jan. 6, 2006). 1. Judge Marcus and The Common Law Privilege Of Pilots Repo

Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed durin

cannot obtain as a matter of constitutional law. Mr. Epstein has performed his side of the bargain with the go

privile e. Nevertheless, we find persuasive the reasoning set forth by the court in Sheldone I. Pennsylvania Turnpike Comnen, 104 F. Supp. 2d 511 (W.D. Pa. 2000), and by other courts that have adopted the federal mediation privilege." Software Tree LLC RedHat Inc., 2010 WL 2788202 at *4 (E.D.Tex. June 24,