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

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 132

intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use, and disclosure of his plea

ntervene. Established case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe 1 and Jane Doe 2 already have remain

morandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective

disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the gove

and trust," and because their confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are "rooted in the imperative need for confidence and trust" and which serve significant public and private ends, have b

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 Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non-Pr

Intervenor Jeffrey Epstein s Motion For a Protective Order And Oppo

during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

—and because their continued confidentiality serves significant public and private ends, they are properly subject to a common law privilege under Federal Rule of Evidence 501. Similar privileges, which are rooted in the imperative need for confidence and trust and which serve significant public and private ends, have bee

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

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges!" Adkins v. Christie, 488 F.3d 1324, 132

d as COnsaa Is binding and ow/ not be Menem arter the CorpOratkrn has made a mid election. (Shareholders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . ..! 1 --1-' 100 1/1/01 12/3 bin, ThUITIMS I UbV UV* I. 2 ( • t1 under penalties or perjury. I declar

-000101 EFTA00227481 imp-u'stuu0 Oi:b0pe Froe-J Epstein i Coapany, Inc T-150 P.004/005 F-135 CERTIFIC

olders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . .

olders sign and date belted Otw Signature Date Jeffrey E. Epstein 6100 Red Hook Qugrte Suite B-3 - . ..

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

st Palm Beach F September 5, 2006 Thank you for your assistance regarding the transcript of the proceedings from the State's grand jury related to Jeffrey Epstein. I have done some additional research regarding the procedures for obtaining the tapes or transcripts from those proceedings.' The cases that I have

s from the State's grand jury related to Jeffrey Epstein. I have done some additional research regarding t

oceedings from the State's grand jury related to Jeffrey Epstein. I have done some additional research reg

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

cument(s) or object(s): Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or , including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by an

July 19, 2006, referring or relating to Jeffrey Epstein and/or , including but not limited to witness t

dnesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or , including but not limited to wi

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court fords this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane

able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic

ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg

(1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410

2011. A FD-302 report was entered on July 5, 2013. See Exhibit A. During the interview process, the FBI agents informed t they had retrieved from Jeffrey E stein's homes, video to es, CDs and DVDs, pictures an documents, that include video tapes of d documents (including but not limited to e-mails and other r

d from the following residences owned by Jeffrey Epstein. 1) 358 El Brillo Way Palm Beach, Florida 3348

e FBI agents informed t they had retrieved from Jeffrey E stein's homes, video to es, CDs and DVDs, picture

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

. See Exhibit A. was interviewed by the FBI on March 17, 2011. During the interview process, the FBI agents informed that they had retrieved from Jeffrey E stein's homes, video to es CDs and DVDs, pictures and documents, that include video tapes of pictures of and documents (including but not limited to e-mai

d from the following residences owned by Jeffrey Epstein. 1) 358 El Brillo Way Palm Beach, Florida 3348

BI agents informed that they had retrieved from Jeffrey E stein's homes, video to es CDs and DVDs, pictures

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela