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

crystal clear that any previously privileged inform- ation actually revealed during the call lost any eneer of privilege. See, e.g., von Bu- low . von Bulow (In re von Bulow), 828 F.2d 4, 102-03 (2d Cir.1987); In re Sealed Case, 676 F.2d 793, 817-18 (D.C.Cir.1982). XYZ does not contest the occurre

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

n there are federal law claims in a case also presenting state law claims, the fed- eral rule favoring admissibility ...I the controlling rule."); von Bulow von Bulow, 811 F.2d 136, 141 ( d Cir.I987) (holding that federal law controlled question of privilege where federal civil RICO claims were jo

numerous allegations, over the span of four years, that Ms. Maxwell participated in a scheme causing her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Pagel 0 of 38 Plaintiff, a public figure required to prove actual malice, liti

and sexual trafficking of minors. Her lawyers intended to prove the defamation claim solely by, in effect, "prosecuting" Ms. Maxwell as a proxy for Epstein. Plaintiff chose this course of action because even she admitted some of her public statements were false. Discovery in the case was correspondingl

ng her to be "sexually abused and trafficked" by Jeffrey Epstein. 2 EFTA00074911 Case 20-2413, Documen

, 828 F.2d 110 (2d Cir. 1987) 20 In re Sims v. Blot, 534 F.3d 117 (2d Cir. 2008) 14 In re Teligent, Inc., 640 F.3d 53 (2d Cir. 2011) 9 In re von Bulow, 828 F.2d 94 (2d Cir. 1987) 14 ii EFTA00074906 Case 20-2413, Document 10-1, 07/30/2020, 2896538, Page5 of 38 Martindell v. Int'l Tel. & Tel. C

f the media and claims to have looked at the journal to "refresh [her] memory about this time." See, e.g., Michael Baker, "The First Women to Report Jeffrey Epstein," The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying to refresh my memory about this time, I came across this journa

vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac

York, NY 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado

e is to protect the adverse "party, the factfinder, and the judicial process from selectively disclosed and potentially misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Ci

State of Michigan Retirement Systems. Filed In Associated Cases: 1:08-md-01963-RWS, 1:08-cv-03351-RWS, 1:08-cv- 03602-RWS, 1:08-cv-08194-RWS(Block, Jeffrey) (Entered: 11/19/2008) 11/19/2008 14 CERTIFICATE OF SERVICE. Document filed by State of Michigan Retirement Systems. Filed In Associated Cases: 1:

the mandamus petition is DENIED because Petitioner has not demonstrated that he lacks an adequate, alternative means of obtaining relief. See In re von Bulow, 828 F.2d 94, 98 (2d Cir. 1987). Catherine O'Hagan Wolfe, Clerk USCA. Issued As Mandate: 11/13/2009. (nd) (Entered: 11/16/2009) 11/16/2009 Transm