Epstein Secrets

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

3 257 F.3d 210 (2d Cir. 2001) United States v. Treacv 19 603 F. Supp. 2d 670 (S.D.N.Y. 2009) STATUTES N.Y. Civil Rights Law § 79-h 3 OTHER 9 James Wm. Moore et al.. Moore's Federal Practice (3d ed. 2010) II EFTA00207336 Daily News, L.P. ("Daily News"), and Daily News journalist George Rush resp

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

3 257 F.3d 210 (2d Cir. 2001) United States v. Treacv 19 603 F. Supp. 2d 670 (S.D.N.Y. 2009) STATUTES N.Y. Civil Rights Law § 79-h 3 OTHER 9 James Wm. Moore et al.. Moore's Federal Practice (3d ed. 2010) II EFTA00728013 Daily News, L.P. ("Daily News"), and Daily News journalist George Rush resp

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

to third persons_does not waive—ffe work-pmdiietimmuniV unless it hes sub- stanti eased—the opportunities ir tent ies to obtain the informa- l; 6 James Wm. Moore, et Moore's Federal Practice § 26.70[6][c] (3d ed.2004) at 26-167 ("Because the work product privilege is intended to protect the adversar