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LORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, 1. UNITED STATES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs' lawyers filed Pla
d allow Professor Dershowitz to intervene. At the very end, on page 38, the Plaintiffs quote from a 2007 plea and settlement negotiation letter that Epstein's defense lawyers sent to the government. The quote, in its entirety, is five or six words. The quote is redacted from the public filing but it is
Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein 17 EFTA00210733 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 18 of 18 CERTIFICATE OF SERVICE I HEREBY CERTIFY tha
TES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICA
ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, throug
Bar No. 0042201 [email protected] On behalf of Jefrey Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jay Epstein 17 EFTA00210733 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page 18 o
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
f Intervenors Roy Black and Jay Lefkowitz MARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 By /S/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 On Behalf ofIntervenor Martin Weinberg 13 EFTA00205554
THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, 1. Plaintiffs, 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
8/2015 Page 4 of 4 Florida Bar No. 126088 rblack @royblack.com JACKIE PERCZEK, ESQ. Florida Bar No. 0042201 jperczek@ royblack.com On behalf of Jeffrey Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 owlmgw @att.net On behalf of Jeffrey
No. 0042201 jperczek@ royblack.com On behalf of Jeffrey Epstein MARTIN G. WEINBERG, P.C. By: s/Marti
need to be publicly filed because they show that Mr. Epstein's lawyers "pushed prosecutors to agree to a confi
r No. 0042201 jperczek@ royblack.com On behalf of Jeffrey Epstein MARTIN G. WEINBERG, P.C. By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 owlmgw @att.net On behalf of Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was filed by my of
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
RG, P.C. 14 EFTA00211556 Case 9:08-cv-80736-KAM Document 385 Entered on FLSD Docket 04/22/2016 Page 15 of 15 By: Is/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 owlmgw@attnet On behalf of Jeffrey Epstein CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was filed by my off
LORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICATION FOR SUPPLEMENTAL PROTECTIVE ORDER A few days ago, on January 21, 2015, the plaintiffs' lawyers filed Pla
d allow Professor Dershowitz to intervene. At the very end, on page 38, the Plaintiffs quote from a 2007 plea and settlement negotiation letter that Epstein's defense lawyers sent to the government. The quote, in its entirety, is five or six words. The quote is redacted from the public filing but it is
TES OF AMERICA, : Defendant. LIMITED INTERVENOR JEFFREY EPSTEIN'S RESPONSE TO ORDER REQUESTING JUSTIFICA
ar tactics before. In prior civil litigation with Mr. Epstein, one of plaintiffs' lawyers, Mr. Edwards, throug
20 Park Plaza Suite 1000 Boston, MA 02116 Telephone: (617) 227-3700 Fax: (617) 338-9538 By: s/Martin G. Weinberg MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 [email protected] On behalf of Jeffrey Epstein 17 EFTA00600031 Case 9:08-cv-80736-KAM Document 295 Entered on FLSD Docket 01/26/2015 Page
DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT THE REMEDY STAGE OF THESE PROCEEDINGS Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) a
the stage at which the Court will consider what remedy to order if it finds that the government violated the plaintiffs' rights under the CVRA. Mr. Epstein does not seek to intervene generally in the case, as the duties and obligations imposed by the CVRA apply solely to the government; the statutory r
UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR PROSPECTIVE LIMITED INTERVENTION AT
violated the plaintiffs' rights under the CVRA. Mr. Epstein does not seek to intervene generally in the case,
ARTIN G. WEINBERG, ■. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By: _/s/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 11 EFTA00617890
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
Suite 1000 Boston, MA 02116 Telephone: (617) 227-3700 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
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
ARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By r IM 1 ARTIN G. WEINBERG, ESQ. Massachusetts Bar No. c 11 iieD 3 BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. 201 South Biscayne Boulevard Suite 1300 Miami, Florida 33131 Office: (305 -1-u21 Fax:
tioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epsicin during a federal criminal investigation. [DE 50 at 51. Doe 1 and Doe 2 seek to use these letters as evidence in this civil matter, and request the
ws.' Some of the lawyers who represented Jeffrey Epstein during the federal criminal investigation and wh
Attorney's Office and the lawyers who represented Jeffrey Epsicin during a federal criminal investigation.
o certify that a copy of the foregoing was sent via separate email to all counsel of record. Respectfully submitted, MARTIN G. WEINBERG, P.C. By Massachusetts Bar No. ci 91210 ARTIN G. WEINBERG, ESQ. BLACK, SREBNICK, KORNSPAN & STUMPF, P.A. By ROY BLACK, ESQ. Florida Bar No. 919063 EFTA00212730
put before the judge in each proceeding. [Doe v. Epstein, Case No. 9:08- CV-80893, DE 226 at 4]. Jane Doe
ARTIN G. WEINBERG, P.C. 20 Park Plaza Suite 1000 Boston, MA 02116 Office: (617) 227-3700 Fax: (617) 338-9538 By /S/ MARTIN G. WEINBERG, ESQ. Massachusetts Bar No. 519480 On Behalf of Intervenor Martin Weinberg KIRKLAND & ELLIS, LLP 601 Lexington Avenue New York, New York 10022 Office: (212) 446-4970 Fax:
Entities connected to both Jeffrey Epstein and Massachusetts Bar No
Leon Black
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Prince Charles
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Jay Lefkowitz
PERSON
Bradley Cooper
PERSON
Scarlett Johansson
PERSONRoy Black
PERSONEmmy Taylor
PERSONJack Scarola
PERSON
Apple
ORGANIZATION