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— a similar effort to intervene on a "reputational" claim. That claim was made by Bruce Reinhart who — like Dershowitz — had previously represented Jeffrey Epstein's interests in related litigation. Reinhart moved to intervene in this case to contest the victims' allegations that Reinhart (a former prosecutor in
attempted to block discovery of materials in this case, leading to an Eleventh Circuit ruling that the victims' discovery efforts were proper. Doe'. Epstein, 749 F.3d 999 (1 1 th Cir. 2014). 3 Remarkably, even though the Court directed the Government to begin producing discovery in June 2013, the Govern
e criminal prosecution broke) Dershowitz stated "I'm on my 20th book. . . . The only person outside of my immediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Dershowitz has also been quoted as saying that, even if Epstein went bankrup
n asked: Do you know what Jeffrey Epstein's relationship is with Alan Dershowitz? That's somebody [i.e., Dershowitz] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexua
in took the Fifth when asked during his deposition "[h]ave you ever socialized with Alan Dershowitz in the presence of females under the age of 18?" Jeffrey Epstein Depo. at 90, Epstein'. Edwards, No. 502009CA040800XXXXMB (Palm. Beach Cty. Cir. Ct. Mar. 17, 2010) (excerpts attached as Exhibit 24). Indeed, going a ste
tance. She was sexually trafficked and abused by Mr. Epstein (and others at the direction of Mr. Epstein) not
ediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein, by Vicky Ward, in Vanity Fair (Jan. 2005)21 Der
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United St
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law.3 Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
s ttorney's Office Southern District of Florida Jeffrey Epstein Dear We write as counsel to Jeffrey Eps
very special thanks to generous support gil et”ey Epstein. for making this meeting happen. This meeting wa
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice, minors. United S
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
ourl Subject: Jeffrey Epstein Illt hope you had a great holiday season. Gerald Lefcourt and I would like to speak with you early next week on the Epstein matter. if you provide me with some convenient dates and times for us to call you, I will coordinate with Gerry and confirm same. regards Lilly A
_CE08_00079 EFTA00184637 9:08-cv-80736-KAM Document 361-46 Entered on FLSD Docket 02/10/2016 Page 5 of 24 LAW DAVICCII or ALD B. LEFCOURT. PC. Jeffrey Matthew Esq. Andrew Laurie. Esq. Esq. The United States Attorney's Office Southern District of Florida July 6, 2007 Page 4 The bulk impor
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
. Declining To Prosecute as an Exercise of Discretion Epstein is being prosecuted by state authorities in Florida. Even if we assume aiguendo that Epslein's conduct constitutes a federal crime that can be proven, nevertheless no "substantial Federal interest" would be served by prosecuting him. On this
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who 'knowingly' persuade or entice, or attempt to persuade or entice minors. United St
RENATO C. STABILE ada•Okoltostaa. corn FAITH A. FRIEDMAN Mearnageskeurstet teen BY FEDERAL EXPRESS ear T essrs. oman, T enc e an July 6, 2007 rey Epstein uric and Ms. Villafaila: HONE I/ zJ 7370400 FAcSIMILE 421211388.6102 We %Tice as counsel to Jeffrey Epstein to follow-up on our meeting on Ju
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law.5 Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. I stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading o
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. I stretched to rea
FAcSIMILE 421211388.6102 We %Tice as counsel to Jeffrey Epstein to follow-up on our meeting on June 26,
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who ' owingly' persuade or entice, or attempt If to persuade or entice, minors. Unite
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law.5 Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
ERAL EXPRESS TELEPHONE FACSIMILE July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attor
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or enticesminors. United St
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
hen it enacted this law? Though §2422(b) is susceptible to multiple interpretations, it was designed to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to reach beyond the core concern of the statute, a host of problems immediately arise. A simple reading
nalccostlawcom BY FEDERAL EXPRESS July 6, 2007 Jeffrey Sloman, Esq., First Assistant United States Attor
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who `knowingly' persuade or entice, or attempt to persuade or entice minors. United St
pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff Jane Doe has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this
prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[
on PACER. S.D. Fla. Civil Docket for Jane. Doe v. Jeffrey Epstein. Case # 9:08-cv- 80893-KAM ("Docket"), DE
on that any of those people . . . have spoken to Mr. Epstein about Jane Doe or any of the other specific victi
§ 79-h(b), (c).° But the Court need not even consider the scope of the reporter's privilege or if it has been waived. Without relying on an explicit First Amendment, common law or statutory privilege, under Rules 26 and 45, federal courts have nonetheless factored in the burden on First Amendment rights when an
ve Order pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this
prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[
found on PACER. S.D. Fla. Civil Docket for ME v. Jeffrey Epstein, Case # 9:08-cv- 80893-KAM ("Docket"), DE
on that any of those people . . . have spoken to Mr. Epstein about or any of the other specific victims," Edw
§ 79-h(b), (c).° But the Court need not even consider the scope of the reporter's privilege or if it has been waived. Without relying on an explicit First Amendment, common law or statutory privilege, under Rules 26 and 45, federal courts have nonetheless factored in the burden on First Amendment rights when an
FLORIDA CASE NO. 08-80736-CIV-MARFtA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN=S RESPONSE To ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs= lawyers filed P
lawyers and parties in this case are already bound by a Protective Confidentiality Order issued by this Court on September 21, 2014, finding that AEpstein has shown good cause to prevent potential dissemination of the correspondence between the government and the intervenor to the press for the purpos
TATES OF AMERICA, Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN=S RESPONSE To ORDER REQUESTING JUSTIFICA
ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs= lawyers, Mr. Edwards, throug
rted not only by the Eleventh Circuit cases cited throughout this pleading but also by the Supreme Court, which upheld a protective order against a First Amendment challenge finding that information learned during the discovery process is not subject to public release in part because of the risk that informati
w best to use the broad discretion you enjoy in choosing whether to prosecute. In this regard, we suggest that having a greater understanding of who Jeffrey Epstein is as a person may help inform how best to proceed. Jeffrey Epstein was raised in a middle class neighborhood in Brooklyn, New York, by hardworking
ralian Avenue, Suite 400 West Palm Beach, Florida 33401 TELEPHONE FACSIMILE Jeffrey Epstein Dear Messrs.= and and Ms. We write as counsel to Epstein to follow-up on our meeting on June 26, 2007. We thought the meeting was extremely productive and appreciate your giving us the opportunity to enga
Palm Beach, Florida 33401 TELEPHONE FACSIMILE Jeffrey Epstein Dear Messrs.= and and Ms. We write as
igned to address a specific a problem with which Mr. Epstein's case has nothing in common. If stretched to re
is addressed to those who purposely and intentionally target children. Here, there was no such targeting. As the Sixth Circuit said in rejecting a First Amendment challenge to the statute: "The statute only applies to those who 'knowingly' persuade or entice, or attempt to persuade or entice, minors. United S
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