Epstein Secrets

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

very of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at '2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. 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 Jeff

sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negot

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

ery of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at *2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation

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

very of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery) must fail. Id.; accord Reist, 2010 WL 4940096 at '2 (recognizing the chilling effect that discovery can have on the willingness of parties to enter into settlement negotiations

TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. 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 5]. 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

UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO

during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D

ery of admissible evidence and the defendants have not made any showing to the contrary, this justification for [discovery] must fail. Id.; accord Reist, 2010 WL 4940096 at *2 (recognizing the "chilling effect" that discovery can have on the willingness of parties to enter into settlement negotiation

Michael J. Davis, Michael Jacoby JEGE, Inc 00000487244 Andrew Galivan, Michael J. Neptune, LLC 00000487264 Andrew Galivan, Michael J. The 2007 Jeffrey E. Epstein 11/1/2013 Armen Brash, NES, LLC 00000487265 Andrew Galivan, Michael J. Plan D, LLC 00000487219 Andrew Galivan, Michael J. Stewart Oldfield

Andrew Galivan, Michael J. The 2007 Jeffrey E. Epstein 11/1/2013 Armen Brash, NES, LLC 00000487265

00000487264 Andrew Galivan, Michael J. The 2007 Jeffrey E. Epstein 11/1/2013 Armen Brash, NES, LLC 0000

00000487264 Andrew Galivan, Michael J. The 2007 Jeffrey E. Epstein 11/1/2013 Armen Brash, NES, LLC 00000

CT Treasury Portfolio. -2 Armen Brash, Andrew Galivan, Michael J. Davis, Michael Jacoby New York US-Onshore Update Required 75413 00000179446 Reist, Derrick Kim Hart REIST, J&L RELATIONSHIP 6/3/2016 Plea se see ACU comment There is no contact with this client. He is a "mutual fund only" clien