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08CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPORTIN COMES NOW, Intervener,.. and files s Response endant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the
y's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 documen
RCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381A)OC STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civ
as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s
09454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPO
signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any
ed Cases District Court of Appeal has authority to issue stay for purpose of preserving status quo during appel- late proceeding. West's F.S.A. R.App.P.Rule Page 1 9.310(0. [2) Appeal and Error 30 C=479(1) 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by Co
all those conditions you two have agreed to? MS. BELOHLAVEK: Yes, Your Honor. MR. GOLDBERGER: With the court's amendments, yes. THE COURT: Mr. Epstein, do you understand? THE DEFENDANT: Yes, ma'am. THE COURT: I need the defendant to 14 sign number D where I had an a added to 15 victim, and G,
Z.= TO REORDER CALL 9546/49599 EFTA00180769 PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein Plea: Guilty _1S Case No. Charge Count Lesser Decree 06CF009454AMB Felony Solicitation of Prostitution 1 No 3 FEL 08CF009381AMB Procuring
tkido by them. . Instructed byt op/07.02.08 Superela& Moor pbfeackt jagt 7 of 8 Form Itovike 034 tiet EFTA00180788 11/LO/Zdtlti 333 ,a4g2 JEFFILEY EPSTEIN CASE(1302008CF009381A.XXX148 • COURT °BMW PA'YMZIff$ • • • ▪ • • • • . . l••111,AI. I •IT\olkl•ILI "Vom Wen sms • . . • ' i . .
ECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein Plea: Guilty _1S Case No. Charge Coun
as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s
: With the court's amendments, yes. THE COURT: Mr. Epstein, do you understand? THE DEFENDANT: Yes, ma'am.
ed Cases District Court of Appeal has authority to issue stay for purpose of preserving status quo during appel- late proceeding. West's F.S.A. R.App.P.Rule Page I 9.310(f). (21 Appeal and Error 30 £=479(1) 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by C
4AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY INTERVENER'S AND S ON TO STAY OF LAW COMES NOW, Intervener, M. and fil 's Response ndant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the
y's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 26 Southern District of Florida for. any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 docume
signed off and said they 15 will not prosecute Mr. Epstein in the 26 Southern District of Florida for. any
IRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, M. and requests this Court, pursuant to Florida Rule of Civ
as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s
ed Cases District Court of Appeal has authority to issue stay for purpose of preserving status quo during appel- late proceeding. West's F.S.A. R.App.P.Rule Page 1 9.310(0. [21 Appeal and Error 30 €=479(1) 30 Appeal and Error 301X Supersedeas or Stay of Proceedings 30k476 Upon Allowance by Co
e reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p
entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described
onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma
ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe
e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO
Club, 145 F.3d 114, 117 (2d Cir.1998); see United States Crispo, 306 F.3d 71, 86 (2d Cir. 002) (applying this rule to a criminal appeal); Fed. R.App. P. 28(b). VII. CUMULATIVE EFFECT [44] Fell contends that even if none of the alleged errors warrants reversal, the cu- mulative effect of the gov
HE INDICTMENT On April , 2008, a Grand Jury sitting in the Southern District of Florida returned a twenty-nine-count indictment charging defendant Jeffrey Epstein' with one count of conspiracy to use a means of interstate commerce to persuade, induce, or entice nineteen minors to engage in prostitution, in vio
under 18 years of age, in violation of 18 U.S.C. § 2423(b). Jane Does #1 through #19 were all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the remaining Jane Does were all residents of Palm Beach County, Florida, at the time of their involvemen
all minors at the time of their involvement with defendant Epstein. Jane Doe #11 was a resident of New York; the re
FLORIDA Case No. UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, Defendant. Notice of Appeal From Magis
ge as continuing to create the historial presumption rinstdeten- tion *1033 (United States Provenzano, 605 F.2d 85, 94 (3d Cir.1 9)), in 1972 Fed.R.App. ("Rule 9(c) was adopted ex- pressly (1972 Advisory Committee Notes to that Rule): to allocate to the defendant the burden of establishing that h
om the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (113) In or around the last half of 2004, Defendantr FREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA00191745 (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instruc
nd the New York residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. 6 EFTA00191729 Manner and Means 29. The manner and means by which the Defendants and other participants sought to accompli
t 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. DefendRJEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. Defendant JEFFREY EPS
JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 t
ose of delay; the defendant bore the burden of showing he would not flee and was not a danger to any person or the community. See also former Fed.R.App.P. 9(c). The Act changed the criteria for release on bail pending appeal and placed the burden on the convicted defendant to prove that he meets
e of their plea negotiations; and, if so, whether a privilege bars crime victims from discovering plea negotiations. The United States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit agai
tates investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit against the United States to enforce their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, and sought to disc
CA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from t
after either issuance of mandate or filing with the U.S. Supreme Court of a petition for a writ of certiorari (whichever is later). Pursuant to Fed.R.App.P. 39 costs taxed equally against appellants and appellees. The Bill of Costs form is available on the internet at www.ca I 1 .uscourts.gov For que
e of their plea negotiations; and, if so, whether a privilege bars crime victims from discovering plea negotiations. The United States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit agai
tates investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit against the United States to enforce their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, and sought to disc
CA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from t
after either issuance of mandate or filing with the U.S. Supreme Court of a petition for a writ of certiorari (whichever is later). Pursuant to Fed.R.App.P. 39 costs taxed equally against appellants and appellees. The Bill of Costs form is available on the internet at www.ca I 1 .uscourts.gov For que
e of their plea negotiations; and, if so, whether a privilege bars crime victims from discovering plea negotiations. The United States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit agai
tates investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit against the United States to enforce their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, and sought to disc
CA, Defendant, ROY BLACK, MARTIN G. WEINBERG, JEFFREY EPSTEIN, Intervenors-Appellants. Appeals from t
after either issuance of mandate or filing with the U.S. Supreme Court of a petition for a writ of certiorari (whichever is later). Pursuant to Fed.R.App.P. 39 costs taxed equally against appellants and appellees. The Bill of Costs form is available on the internet at www.ca I 1 .uscourts.gov For que
S. 427, 87 S.Ct. 1 , 18 L. Ed.2d 865 (1967); Buchanan Rhodes. 885 U.S. 3, 87 S.Ct. 83, 17 .Ed.2d 9 (1966); Idlewild Bon Voyage Liquor Corp. v. Epstein, 370 U.S. 713, 82 S.Ct. 1294, 8 L.Ed2d 794 (1962). Since in this case we affirm that refusal, we need not now decide whether or not there is juri
, Gary A. Hughes, J.D, Steven D. Najarian, J.D., Jeffrey A. Schafer, J.D., and Jeffrey J. Shampo, J.D. II
d to withhold issuance of the mandate herein until seven days after resolution of any timely petition for rehearing or rehearing en bane. See Fed. R.App. P. 41(b); D.C.Cir. R. 41. C.A.D.C..2006. Miranda I. Gonzales 173 Fed.Appx. 840, 2006 WL 592928 (C.A.D.C.) END OF DOCUMENT C 2007 Thomson/West.
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