Epstein Secrets

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

Case No. 09-60726-CIV-30ltDAN/MCALI- LEY. 3. The motion is fully titled Request for Judi- cial Inquiry Into Perjury, and Potential Subor- nation of Perjury and Witness Tampering. IDE 103]. EFTA00177860 EL-AD RESIDENCES AT MIRAMAR CONDOS. MT. HAWLEY 1259 CIloas716 F.Supp.2d 1257 (S.D.FIa. 2010) sui

upposedly took place (1994-1997). The plaintiff in the defamation action, made wild and false accusations that she had been sexually trafficked by Epstein and Ms. Maxwell to dozens of famous politicians, professors, foreign leaders, and others. When Ms. Maxwell denied these allegations as false, sued

OF THE ALLEGATIONS A. Counts One through Four (the "Mann Act Counts") Counts One and Three of the Indictment allege that Ms. Maxwell conspired with Jeffrey Epstein and "others known and unknown" to violate two separate provisions of the Mann Act. Count One alleges that Ms. Maxwell conspired with Epstein to enti

OUNTS FIVE AND SIX OF THE SUPERSEDING INDICTMENT Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

of knowledge about undefined "devices" or "toys" could possibly "conceal her crimes." Accordingly, the government's purported connection between the Perjury Counts and the Mann Act Counts defies logic and is insufficient to permit joinder under Rule 8(a). See Botti, 2009 WL 3157582, at *5 (joinder impro

oing she quit watching. I forwarded a request to Jeffrey Maddox, Office of Telecommunications Security an

ursue charges through the Office of Student Rights and Responsibilities in lieu of pursuing criminal charges. Velasquez was charged criminally with Perjury, Not in an Official Proceeding, 837.012, F.S., Misdemeanor 1st. INVESTIGATIVE ENTRIES; On 1/11/06 Jacqui Pequignot, Director, FSU Victim Advocate