Epstein Secrets

rent victims have responded by explaining how these documents are relevant, including explaining how these documents might bear on the way in which Epstein used his powerful political and social connections to secure a favorable plea deal, as well as provide proof of the Government's motive to delibera

d be as interested in him as a friend if we had hamburgers on the boardwalk in Coney Island and talked about his ideas.- Vanity Fair Reminds Us When Jeffrey Epstein Warn 't a Creep. by Ray Gustini, in The Wire (June 21, 2011). Second, Jeffrey Epstein brazenly abused numerous girls in his Florida mansion, his New Yo

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).11 Dershowitz has also been quoted as saying that, even if Epstein went bankru

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 was in Jeffrey Epstein's bedroom getting sexually

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 Isr• 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 step

. Dershowitz had sex with minors in concert with Mr. Epstein. Only Prof. Dershowitz is situated to protect hi

ediate family that I send drafts to is Jeffrey." The Talented Mr. Epstein. by Vicky Ward, in Vanity Fair (Jan. 2005).11 De

tervention by a person who has "a claim or defense that shares with the main action a common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley Ins. Co. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311 (1Ith Cir. 2005) (permissive intervention allowed only where "a claim or defense and the mai

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

TA00177878 Case 9:08-cv-80736-KAM Document 93 Entered on FLSD Docket 09/02/2.011 Page 2 of 9 See El-Ad Residences at Miramar Condo. Ass'''. Inc. I Mt. Hawley Ins. Co., 716 F. Supp. 2d 1257, 1262 (S.D. Fla. 2010), quoting In re Grand Jury Subpoena (Newparent Inc.), 274 F.3d 563, 570 (1st Cir. 2001) (in the co

case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"

REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who

n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros

ubstantial, legally protectable interest in the proceedings." Purcell v. Bank/Mantic Financial Corp., 85 F.3d 1508, 1512 (I I th Cir. 1996); accord Mt. Hawley Ins. Co. v. Sandy Lake Properties, Inc., 425 F.3d 1308 (1Ith Cir. 2005). The The defense attorneys have not claimed that they should be permitted to int

iv. P. 24(b)(1)(b) (doc. #79). The motion to intervene should be denied. appears to be merely the cat's paw of a possible real party in interest — Jeffrey Epstein. It is of no concern to whether or not this Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the Crime Victims'

d of "common question of law or fact" sufficient to support his permissive intervention into this case. Accordingly, as with the similar motion for Epstein's defense attorneys, his motion to intervene in this Crime Victims' Rights Act case is without merit and should be denied. Alternatively, if the Co

cat's paw of a possible real party in interest — Jeffrey Epstein. It is of no concern to whether or not

ervention by a person who has "a claim or defense that shares with the main action a common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley Ins. Co. I. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311 (11th Cir. 2005) (intervention allowed only where "a claim or defense and the main action h

-80736-CIV-MARRA/HOPICINS JANE DOE #1 and JANE DOE #2, Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ORDER ON MOTION FOR INTERVENTION BY JEFFREY EPSTEIN THIS CAUSE is before the Court upon the Motion to Intervene For Limited Intervention by Jeffrey Epstein (DE 93). This matter is fully briefed and i

F.3d 1308, 1312 (11th Cir. 2005) (citing Georgia United States Army Corps of Eng'rs, 302 F.3d 1242, 1250 (11i'' Cir. 2002)). Through their Motion, Epstein asks to intervene "for the limited purpose of seeking a protective order and responding to the motions of Jane Doe 1 and Jane Doe 2 for disclosure,

Defendant. ORDER ON MOTION FOR INTERVENTION BY JEFFREY EPSTEIN THIS CAUSE is before the Court upon the

question of law or fact in common and the intervention will not unduly prejudice or delay the adjudication of the rights of the original parties." Mt. Hawley Ins. Co.. Sandy Lake Properties, Inc., 425 F.3d 1308, 1312 (11th Cir. 2005) (citing Georgia United States Army Corps of Eng'rs, 302 F.3d 1242, 1250 (11i

matter, the defense attorneys would suffer no harm from release of the materials. Essentially what the defense attorneys are doing is appearing as Jeffrey Epstein's "next friend" to litigate issues on his behalf. But "a 'next friend' must provide an adequate explanation -- such as inaccessibility, mental incompe

hallenge to the legality of the non-prosecution agreement therefore cannot create a sufficient interest for the defense attorneys to intervene. Only Epstein has an interest in the validity of the non-prosecution agreement, and he has deliberately chosen not to intervene in this case.2 II. THE DEFENSE AT

erns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no rec

substantial, legally protectable interest in the proceedings." Purcell I BankAtlantic Financial Corp., 85 F.3d 1508, 1512 (11th Cir. 1996); accord Mt. Hawley Ins. Co.l Sandy Lake Properties, Inc., 425 F.3d 1308 (11th Cir. 2005). The The defense attorneys have not claimed that they should be permitted to inter

24(b)(1)(b) (DE #79). The motion to intervene should be denied. Reinhart appears to be merely the cat's paw of a possible real party in interest — Jeffrey Epstein. It is of no concern to Reinhart whether or not this Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the Crime

d of "common question of law or fact" sufficient to support his permissive intervention into this case. Accordingly, as with the similar motion for Epstein's defense attorneys, his motion to intervene in this Crime Victims' Rights Act case is without merit and should be denied. Alternatively, if the Co

cat's paw of a possible real party in interest — Jeffrey Epstein. It is of no concern to Reinhart whether

ervention by a person who has "a claim or defense that shares with the main action a common question of law or fact." Fed. R. Civ. P. 24(b); accord Mt. Hawley Ins. Co. v. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311 (11th Cir. 2005) (intervention allowed only where "a claim or defense and the main action h

-80736-CIV-MARRA/HOPICINS JANE DOE #1 and JANE DOE #2, Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ORDER ON MOTION FOR INTERVENTION BY EPSTEINS' ATTORNEYS THIS CAUSE is before the Court upon the Motion to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz ("Epstein's Attorneys") (DE

question of law or fact in common and the intervention will not unduly prejudice or delay the adjudication of the rights of the original parties." Mt. Hawley Ins. Co... Sandy Lake Properties, Inc. 425 F.3d 1308, 1312 (11th Cir. 2005) (citing Georgia United States Army Corps of Eng'rs, 302 F.3d 1242, 1250 (11i