Epstein Secrets

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

ful chart listing the documents used to prepare each of the witnesses. Eleven were used to prepare Sharbaugh 32 to prepare Dr. Henderson, five for Picard, two for Todd Henderson, and nine for Fara. With the exception of document no. 23, for which the attorney client privilege was as- serted, plainti

uments *e- 1 viewed by Sharbaugh, and the documents reviewed by Dr. Henderson, except for no. 23, shall be disclosed. The motion to com- pel as to Picard, Todd Henderson and Fara is denied. Plaintiffs will make the ordered disclosures within 14 days of this order. In addition, I will permit a limite

e: Address: UNITED STATES Event: • SEX - Sex Offenses (Rape, Sodomy, Sexual Abuse, Pedophilia) ACC - Accuse . accused of being a coconspirator of Epstein of multiple counts of five federal offenses involving sex acts with minors Source Information RDC URL: https //grid.rdc com/wssientity.html?entity

ervice - (United States) 10/17/2009 MICHELE DARGAN Daily News Staff Writer I Copyright 2009 Cox News Service, All Rights Reserved. Bernie Madoff, Jeffrey Epstein. Conrad Black and Michael Kagdis court cases evolve One Palm Beach-related court case wrapped up last month when Lin Gosman, wife of former health-c

ews Service, All Rights Reserved. Bernie Madoff, Jeffrey Epstein. Conrad Black and Michael Kagdis court ca

20 SDNY_GM_00053521 CONFIDENTIAL - PURSUANT TO FED. R.QQN(F IDENTIAL DB-SDNY-0016345 EFTA_00 I 64 I 02 EFTA01294894 rdc Entity: In the suit, Picard is seeking nearly $200 million to be returned to Bernard Madoffs victims. In July, Picard sued Bernard Madoffs wife, Ruth. seeking 545 million. Pic

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Fwd: Alert: Cay

From: Richard Kahn To: "Jeffrey E." <[email protected]> Subject: Fwd: Alert:

stee because, "innocent as he may be, he acts as the debtor's representative." In re Bernard L. Madoff Securities, LLC, 721 F.3d 54 (2d Cir. 2013). Picard unsuccessfully argued that the "adverse interest" exception prevented BLMIS's wrongdoing from being imputed to him. The adverse interest exception i

eption based on its finding that the fraud was not committed against BLMIS, but on its behalf. Consequently, the wrongdoing of BLMIS was imputed to Picard, which in turn barred him from bringing claims for intentional wrongdoing on behalf of BLMIS against third parties. Over the last few years, the in

t declined 5.3%. FORM chief operating officer is Jeffrey Bowers, who previ- ously worked at hedge fund man

10,2019 Platforms _Rem Page 4 emerged as "infrastructure plays," offering investors easy access to hedge funds through a managed-account format, Picard said. Compared to traditional multi-manager vehicles such as funds of funds, managed account platforms give investors more control when it comes t

Bernard Madoffs victims. In July, Picard sued Bernard Madoffs wife, Ruth, seeking $45 million. Picard also filed a lawsuit against philanthropists Jeffry and Barbara Picower in May. In the lawsuit, Picard accuses the Picowers of knowing about and benefiting from the fraud. Bernard and Ruth Madoff hav

rdc Entity In the suit, Picard is seeking nearly $200 million to be returned to Bernard Madoffs victims. In July, Picard sued Bernard Madoffs wife, Ruth, seeking $45 million. Pic

Bernard Madoffs victims. In July, Picard sued Bernard Madoffs wife, Ruth, seeking $45 million. Picard also filed a lawsuit against philanthropists Jeffry and Barbara Picower in May. In the lawsuit, Picard accuses the Picowers of knowing about and benefiting from the fraud. Bernard and Ruth Madoff hav

rdc Ental In the suit, Picard is seeking nearly $200 million to be returned to Bernard Madoffs victims. In July, Picard sued Bernard Madoffs wife, Ruth, seeking $45 million. Pic

To: Jeffrey [email protected]] From: David Stem Sent Wed 9/29/2010 12:26:53 PM Lion Said to Price 400 Million-Euro Picard LBO than at 99.75% Blo

. Lion Capital, the owner of breakfast cereal Weetabix, is raising 675 million euros from loans and Soo million euros from high-yield bonds for the Picard deal, according to data compiled by Bloomberg. The bonds may be priced to yield between 9 percent and 9.25 percent. Picard, based in Fontainebleau,