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oe 1 and Jane Doe 2 complain that the government treated them unfairly by not keeping them involved in the government's settlement negotiations with Jeffrey Epstein. They seek to invalidate the Non-Prosecution Agreement between Mr. Epstein and the government, claiming that the agreement violates the Crime Victi
ng them involved in the government's settlement negotiations with Jeffrey Epstein. They seek to invalidate the Non-Prosecution Agreement between Mr. Epstein and the government, claiming that the agreement violates the Crime Victims's Rights Act. Jane Doe I and Jane Doe 2 seek disclosure of all the lette
in the government's settlement negotiations with Jeffrey Epstein. They seek to invalidate the Non-Prosecu
invalidate the Non-Prosecution Agreement between Mr. Epstein and the government, claiming that the agreement
pril 17, 2012, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami. Florida 33131 By /S/ ROY BLACK, ESQ. Florida Bar No. JACKIE PERCZEK,
rvenors Black, Weinberg, and Lefkowitz until Friday, August 26 to file supplemental briefing on the issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural is
lemental briefing on the issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so that there are no procedural issues regarding whether the protections and policies relating to Fede
issues raised concerning plea negotiations with Jeffrey Epstein. Also following the hearing, the decision
following the hearing, the decision was made for Mr. Epstein to file a motion seeking limited intervention so
gust 22, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN Miami, Florida 33131 By /S/ ROY BLAC ES . Florida Bar N JACKIE PERCZEK, ESQ. Florida Bar No 2 EFTA00205988
CT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs I. UNITED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANCE AT OR PARTICIPATION IN SETTLEMENT CONFERENCE Intervenor Jeffrey Epstein has requested that he be permitted
likely that any meaningful settlement discussions can take place between the plaintiffs and the government without touching on remedy. Granting Mr. Epstein, through counsel, the right to participate in the settlement conference is necessary to effectuate Judge Marra's order granting Mr. Epstein's motion
ED STATES OF AMERICA, Defendant / INTERVENOR JEFFREY EPSTEIN'S MEMORANDUM IN SUPPORT OF HIS ATTENDANC
government without touching on remedy. Granting Mr. Epstein, through counsel, the right to participate in the
y has the discretion to permit him to participate in the settlement conference and should exercise that discretion. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. By: /s/ ROY BLACK, ESQ. Florida Bar No. 126088 [email protected] JACKIE PERCZEIC, ESQ. Florida Bar No. 042201 jpe
THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. EPSTEIN'S REPLY IN SUPPORT OF SUPPLEMENTAL PROTECTIVE ORDER There is no doubt that the Eleventh Circuit has held that Epstein's plea negotiation and settle
ack Roy BLACK, ESQ. Florida Bar No. 126088 [email protected] JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 [email protected] On behalf of Jeffi•ey Epstein MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Telephone: (617) 227-3700 EFTA00583387 Fax: (617) 338-9538 By: s/Marti
EFTA00583387 Fax: (617) 338-9538 By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was filed by my office via CM/ECF, this 26th day of January, 2015. By:
need to be publicly filed because they show that Mr. Epstein's lawyers "pushed prosecutors to agree to a confi
separation of powers between the executive and judicial branches (as argued by the Government, see DKT 290 at 11). Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Telephone (305) 371-6421 Fax (305)358-2006 By: s/Roy
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
tember 2,2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305) 371-6421 Fax: (305) 358-2006 By /S/ ROY
necessary" (doc. #17 at I). The Office asserted that the Court need only take judicial notice of the fact that no indictment had been filed against Epstein to resolve the case. On August I, 2008, the victims filed a response to the Government's "Notice" (doe. #19), giving a proposed statement of facts
n for sexually abusing them. During the course of that litigation, in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July 2010. During the settlement discussions, they informed Epste
hether a charging document was ever filed against Jeffrey Epstein in the United States District Court for
in "the same position as they would have been had Mr. Epstein been convicted at trial." Declaration of Marie V
April 7, 2011, the foregoing document was filed electronically with the Clerk of the Court using the CM/ECF system. Respectfully submitted, BLACK, SREBNICIC, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305) 371-6421 Fax: (305) 358-2006 By /S/ ROY
Entities connected to both Jeffrey Epstein and SREBNICIC
Leon Black
PERSON
Prince Andrew
PERSON
Woody Allen
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSONRoy Black
PERSONJack Scarola
PERSON
Michael Douglas
PERSON
Southern District of New York
ORGANIZATION
Supreme Court
ORGANIZATION