Epstein Secrets

f his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

tates receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. (NPA, paragraph 13(emphasis added.) The first sentence of the above quote does no more than state an expectation b

8:4 15:19 11:19,24 1:17 2:10,11 moment 13:24 3:10 2:13 15:16 hur Jack Lauderdale months Hafele 4:24 2:2 4:5 2:14,21 13:20,21 10:10 Jeffrey leave morning I half 1.11,17 3:4 8:14 3:20,21 idea 13:20 14:21 4:6 let's motion handed 5:16 JA 8:6 11:11 4:7 6:2 7:6 5:13 9:1 imme

have signed off and said they will not prosecute Mr. Epstein in the Southern District of Florida for any offe

use by teacher on minor pu- pil). Compare Freehauf I School Board of Seminole County, 623 So.2d 761 (Fla. 5th DCA)cause dismissed, 629 So.2d 132 (Fla.1994) (Suit for abuse inflicted on son by stepmother; failure to retort suspected abuse by school); Fischer 1 Metcalf 543 So.2d 785 (Fla. 3d DCA 1989)

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

isclosure by the attorney-client privilege falls upon the party autillnilike privilege. Bell Tel. & Tel. Co. . Deasoil, 632 So.2d 1377, 1383 I (Fla.1994); Cone I. Culverhouse, 687 So.2d 888, 892 (Fla. 2d DCA 1997) ('The privilege will not apply unless the party asserting it proves that the communic

which of his clients is the purported victim. Accordingly,) will address facts related to , S. and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to III and In

fteenth Judicial Circuit, Palm Beach County, Florida. This charge was based upon the offenses alleged in paragraph 1 of the petition. Second, while Epstein has been under federal investigation, he has not been charged in EFTA00183654 Case 9:08-cv-80736-KAM Document 13 Entered on FLSD Docket 07/15/20

treet, Suite 202 Hollywood, Florida 33020. Re: Jeffrey E eir m/SaVhiii: NOTIFICATION OF IDENTIFIED VICT

ve the federal investigation. al 5. At that time, Mr. Epstein had been charged by the State of Florida with so

abuse by teacher on minor pu- pil). Compare Freehold School Board of Seminole County, 623 So.2d 761 (Fla. 5th DCA)cause dismissed, 629 So.2d 132 (Fla.1994) (Suit for abuse inflicted on son by stepmother; failure to report suspected abuse by school); Fischer , Metcalf 543 So.2d 785 (Fla. 3d DCA 1989)