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 by Judge on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 jail RESPONSE/REPLY tom Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lelkowitz by United States of America. (Villafana, Ann Marie) (Entered: 09/27/2011) 09/28/2011 jaL MOTION for Extension of Time to File Respo

, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefkowitz, to strike the plaintiffs' notice of supplemental authority [DE 173] because the "authority" cited by

a negotiations and therefore her comment is irrelevant. The facts leading up to Ms. Haddad's comment are these: In a separate civil proceeding, Mr. Epstein has sued attorney Bradley Edwards in state court for abuse of process. Jeffrey Epstein is represented in that state civil action by Tonja Haddad; Mr

UTHORITY This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefko

gotiations. This is absurd. The issues raised by Mr. Epstein and the intervening attorneys before this Court i

TES OF AMERICA, Defendant. MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and Lefkowitz, to strike the plaintiffs' notice of supplemental authority [DE 173] because the "authority" cited by the plaintiffs — a comment by

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56), as well as during the August 12, 2011 hearing.

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

s and emails that Jane Doe 1 and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Lefkowitz in their motion to intervene and its attached motion for a protective order [DE 56], as well as during the August 12, 2011 hearing.

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

9:08-cv-80736-KAM Document 93 Entered on FLSD Docket 09/02/2011 Page 3 of 9 First, they argued in their opposition to the intervention of attorneys Black, Weinberg, and Lefkowitz that Mr. Epstein "is the real party in interest" and that "harm from the release of the materials (if any) could be only to Jeffrey

mited Intervenor Jeffrey Epstein And Opposition To Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations by Jeffrey Epstein. (Perczek, Jacqueline) (Entered: 04/17/2012) 04/17/2012 164 SUPPLEMENTAL Briefing in support of Motion for a Protective Order concerning Productio

atabase - flsd Page 4 of 24 Intervenor Jeffrey Epstein represented by Jacqueline Perczek (See above fo

- Live Database - flsd Page 4 of 24 Intervenor Jeffrey Epstein represented by Jacqueline Perczek (See

eth A. Marra on 9/26/2011. (ir) (Entered: 09/26/2011) 09/27/2011 100 RESPONSE/REPLY to 94 Supplement Briefing in Support of Motion to Intervene of Black, Weinberg, and Lefkowitz by United States of America. ( Ann Marie) (Entered: 09/27/2011) 09/28/2011 i (Court only) ***Motions terminated: 41 Plaintiffs MO

Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed durin

cannot obtain as a matter of constitutional law. Mr. Epstein has performed his side of the bargain with the go

RICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed during the litigation on intervention. We only

put before the judge in each proceeding. [Doe v. Epstein, Case No. 9:08- CV-80893, DE 226 at 4]. Jane Doe

ENE OF ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ Jane Doe I and Jane Doe 2 oppose intervention because according to them, proposed intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane Doe I and Jane Doe 2 contend that all the correspondence at issue was alread