Epstein Secrets

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend

the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'

ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea

r a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00205362 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attornevettlement negotiations. In determining whether to grant a stay p ing appeal, the Court is to consider four factors: "(1

emos Epstein's counsel addressed the reasons why Mr. Epstein should not be federally 8 EFTA00205367 The "c

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

r a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00205362 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00205342 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attornevettlement negotiations. In determining whether to grant a stay p ing appeal, the Court is to consider four factors: "(1

emos Epstein's counsel addressed the reasons why Mr. Epstein should not be federally 8 EFTA00205347 The "c

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

r a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00205342 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc.

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

ntinuing exchanges of letters and memos in which Mr. Epstein's counsel addressed the reasons why Mr. Epstein s

63); and Reply in Support of Supplemental Briefing By Limited Intervenors Black, Weinberg, Lefkowitz, and Epstein (Doc. 169). 3 EFTA00583391 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen

prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Jeffrey Epstein through attorney-to-attorney settlement negotiations. The central issue they will raise on appeal is whether communications made during the course

UND. Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and served a prison sentence and a term of community control probation. The agreement, with which he has fu

CTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby request that this Court stay the

and received settlements as the direct result of Mr. Epstein's agreement not to contest liability in those ca

nors to seek a stay pending appeal from this Court (Doe. 206), Exhibit B hereto, which they now do. II. LIKELIHOOD OF SUCCESS ON THE MERITS. A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc.

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

continuing exchanges of letters and memos where Mr. Epstein's counsel addressed the reasons why Mr. Epstein s

ed appellate resolution of the issues presented prior to the release of the communications at issue. I. LIKELIHOOD OF SUCCESS ON THE MERITS.' A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding of the central role of plea bargaining and settlemen