Epstein Secrets

rand tampion. ftbdLiidtddafLS teadi.01444.41a la News Emus.* News Appeals Court Rules in Favor of Crime Victims' Rights in Registered Pedophile Jeffrey Epstein Case In a landmark decision, the US Court of Appeals for the Eleventh Circuit Court on April 18 2014, ruled In favor of two crime victims represented by

tell the girls." U.S. Attorneys Correspondence at 359. The reasonable inference is that the "marching orders" agreed to between the Government and Epsteinls-tiefense-eounsel-was-that-ne-mention-weuld-be-made-octhe-ROli-pfeseeutiewegreement between-the-U,SrAttertieyls-Gfflee-anii-Epsteiur as-fie-subseque

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of Crime Victims' Rights in Registered Pedophile Jeffrey E Epstein Case Posted on Wed, Apr 23,2014 1.1.1/4

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o settle civil suits BY SUSAN SPENCER.WENDEL Pam 80•01 Post Shoff Meer Friday. Seplamber 10.2009 WEST PALM BEACH — fiflonaire Mender sex offender Jeffrey Epstaln's secret non-proseaNch weaned ha 'Ouch with Wein prosecutor, was Waxed Friday. Offering the not pubic look et the deal Epstein's high-powered legal c

t's desire that federal charges be filed against defendant Epstein. In particular, he wrote on behalf of his client

2006 the FBI began investigating allegations that Jeffrey E. Epstein had sexually abused dozens and dozens of

ter-about-the-money isuo, just about what crimes Mr. Epstein is pleading guilty to and the amount of time-tha

ledged the private nature of discovery" Looney I Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11'1' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process becaus

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

6/18/2013 Page 2 of 4 the asserted right of access against the other party's interest in keeping the information confidentiarRomero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11* Cir. 2001). In balancing the competing interests, the court appropriately considers "wheth

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

mit how that information is used in the litigation. We believe this Court's inquiry is guided generally by the following Eleventh Circuit cases: * Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304 (11th Cir. 2001). * FTC v. Abbvie Prod. LLC, 713 F.3d 54, (11th Cir. 2013). * Newman v. Graddic, 696 F

LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of the Federal R

ernment in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and ser

rvenors. INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER AND INCORPORATED MEMORANDUM OF LAW Intervenors Roy Black, Martin Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court for the entry a Protective Confid

ROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and served a prison sentence and a term of community control probation. The agreement, with which he has f

edged the private nature of discovery" Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist. LEXIS 48349, at *3, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1316 (11t' Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private process becau

FLORIDA CASE NO. 08-80736-CIV-MARFtA/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 P

lawyers and parties in this case are already bound by a Protective Confidentiality Order issued by this Court on September 21, 2014, finding that AEpstein has shown good cause to prevent potential dissemination of the correspondence between the government and the intervenor to the press for the purpos

TATES 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

it how that information is used in the litigation. We believe this Court=s inquiry is guided generally by the following Eleventh Circuit cases: * Chicago Tribune Co. v. Bridgestone/Firestone Inc., 263 F.3d 1304 (11th Cir. 2001). * FTC v. Ahhvie Products LLC, 713 F.3d 54, (11th Cir. 2013). * Newman v. Graddic, 69

IN PART and DENIED IN PART. I. Background This action is brought by the alleged victims ("victims" or "petitioners') of sexual crimes committed by Jeffrey Epstein ("Epstein"). The victims allege that the United States Attorney violated their rights under the Crime Victims' Rights Act ("CVRA"), and are seeking

IN PART. I. Background This action is brought by the alleged victims ("victims" or "petitioners') of sexual crimes committed by Jeffrey Epstein ("Epstein"). The victims allege that the United States Attorney violated their rights under the Crime Victims' Rights Act ("CVRA"), and are seeking relief st

or "petitioners') of sexual crimes committed by Jeffrey Epstein ("Epstein"). The victims allege that the

the competing interests of the parties and of the public to inspect the documents upon which the courts make their case dispositive decisions. Id.; Chicago Tribune Co. I. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1311 (I I th Cir. 2001). It is necessary to point out that there is no common law public right of ac

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

er Rule 6(eX3)(AXii) or (iii). 2 EFTA00600055 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

8/2013 Page 2 of 4 the asserted right of access against the other party's interest in keeping the information confidential." Romero at 1246, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304, 1309 (11' Cir. 2001). In balancing the competing interests, the court appropriately considers "wheth