Epstein Secrets

rmation in the civil case, after extended litigation the Court ordered Epstein to produce all correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Because of the delay 2 EFTA00614066 Case 9:08-cv-80736-KAM Document 96 Entered on FLSD Docket 09/16/2011 Page 3 of 21 caused by

24(a) and Fed. R. Civ. P. 24(b) (DE 93). The motion for "limited" intervention should be denied for three separate and independent reasons. First, Epstein's motion is not timely. The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence

RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COME NOW Jane Doe #1 and Jane Doe #2 (al

CVRA case: "At this point there is no reason for Mr. Epstein to become involved in the case where [Jane Doe #1

issues -- Jeffrey Epstein filed his untimely "Motion for Limited Intervention" (DE #93). This document was also signed by attorney Roy Black, Esq. I. EPSTEIN MOTION FOR LIMITED INTERVENTION IS UNTIMELY. The Court should deny Epstein's motion for invention because it is simply untimely. As Epstein concede

ene is denied ... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I.

rmation in the civil case, after extended litigation the Court ordered Epstein to produce all correspondence between the U.S. Attorney's Office and Jeffrey Epstein's legal counsel. Because of the delay 2 EFTA00614087 Case 9:08-cv-80736-KAM Document 96 Entered on FLSD Docket 09/16/2011 Page 3 of 21 caused by

24(a) and Fed. R. Civ. P. 24(b) (DE 93). The motion for "limited" intervention should be denied for three separate and independent reasons. First, Epstein's motion is not timely. The victims very specifically advised Epstein more than one year ago that they would be filing U.S. Attorney correspondence

RESPONSE TO MOTION FOR "LIMITED" INTERVENTION OF JEFFREY EPSTEIN COME NOW Jane Doe #1 and Jane Doe #2 (al

CVRA case: "At this point there is no reason for Mr. Epstein to become involved in the case where (Jane Doe #1

issues -- Jeffrey Epstein filed his untimely "Motion for Limited Intervention" (DE #93). This document was also signed by attorney Roy Black, Esq. I. EPSTEIN MOTION FOR LIMITED INTERVENTION IS UNTIMELY. The Court should deny Epstein's motion for invention because it is simply untimely. As Epstein concede

ene is denied ... [and] 4. The existence of unusual circumstances militating either for or against a determination that the application is timely. Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). All four of the factors suggest that the Court should deny Epstein's motion as untimely. I.

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,

, 194 Fed. Appx. 879, 882 (11th Cir. 2006), and is "not limited to chronological considerations but is to be determined from all the circumstances." Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is s

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 LIMITED INTERVENTION Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1)(3), that he be permitted to intervene for

ure. If the plaintiffs move to compel production of any materials as to which the government has asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continued secrecy of matters which occurred before the two grand juries which investigated the issue of whe

UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein

s asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continue

F.2d 1511, 1516 (11th Cir. 1983). "Timeliness" is "not limited to chronological considerations but is to be determined from all the circumstances." Stallworth v. Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Among the circumstances which must be considered is "the purpose for which intervention is s

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

precise measurable dimensions . . . [T]imeliness is not limited to chronological considerations but is to be determined from all the circumstances." Stallworth 'Monsanto Co., 558 F.2d 257, 263-64 (5th Cir. 1977). Those circumstances are considered in light of four factors: I. The length of time during whic