Epstein Secrets

ed. R. Evid. 501 4, 16 iv EFTA00209469 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ossi City of Memphis, 423 F.3d 596 (6th Cir. 2007) 18 passim 14 passim 13, 15 S.E.C. I. CMKA1 Diamonds, Inc., 656 F.3d 829 (9th Cir. 2011) 15 Sheet Metal Workers Intern. I Sweeney, 29 F.3d 120 (4th Cir.1994) 15 United States' Gonzalez, 669 F.3d 974 (9th Cir. 2012) 14 United States' Krane, 625 F.3d 568 (9th Cir.

ed. R. Evid. 501 4, 16 iv EFTA00209538 Case: 13-12923 Date Filed: 07/12/2013 Page: 6 of 25 INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ossi City of Memphis, 423 F.3d 596 (6th Cir. 2007) 18 passim 14 passim 13, 15 S.E.C. I. CMKA1 Diamonds, Inc., 656 F.3d 829 (9th Cir. 2011) 15 Sheet Metal Workers Intern. I Sweeney, 29 F.3d 120 (4th Cir.1994) 15 United States' Gonzalez, 669 F.3d 974 (9th Cir. 2012) 14 United States' Krane, 625 F.3d 568 (9th Cir.

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass 'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 15 EFTA00583774 D. The United States is a Disinterested Third Party. Under the circu

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4, . Instead, he pled guilty to two state offenses, one of which was a fel

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ity of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass '?7, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 16 EFTA00584618 government and who sought, though full and frank exploration of the fa

07 (emphasis added). This conclusion underscores that inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

ss v. City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing= Inc.., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 8 EFTA00583461 not the privilege for which intervenors contend would, if recognized, e

07 (emphasis added). This conclusion underscores the inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

ircumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

City of Memphis, 423 F.3d 596, 599-600 (6th Cir. 2007); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)(civil case); Sheet Metal Workers Intern. v. Sweeney, 29 F.3d 120, 212 (4th Cir.1994)(civil case). 8 EFTA00583787 represented a private individual under criminal investigation by the go