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

f the mental impressions? conclusions, opin- ions, or legal theories of an attorney or other representative of a party concerning the litigation. The Fourth Circuit has explained that this formulation of the doctrine divides work product into two categories, "fact work product," which may be discovered upon a

nder 18 U.S.C. § 3771(d)(1) that Jane Does 1 through 33 are barred from obtaining relief under the CVRA due to complicity in the crimes committed by Jeffrey Epstein.' Petitioners have withdrawn their third and fourth request for admissions, but still seek four categories of documents in their request for produc

3 through 33 were identified on the list of victims that was prepared by the government pursuant to the terms of the non-prosecution agreement with Epstein. 2 EFTA00618023 Case 9:08-cv-80736-KAM Document 359 Entered on FLSD Docket 02/01/2016 Page 3 of 11 entirely by the government. Despite availing

CVRA due to complicity in the crimes committed by Jeffrey Epstein.' Petitioners have withdrawn their third

ce on the CVRA and the Air Transportation Safety and Stabilization Act as granting authority for the district court to allow discovery. Id. at 234. The Fourth Circuit observed that, "[t]his was wise strategy, as nothing in those two statutes support the district court's exercise of power." Id. The appellate court

Westlaw Delivery Summary Report for DOYLE,LEA Dateffime of Request: Thursday, March 3, 2011 12:32 Eastern Client Identifier: EPSTEIN Database: FEDFIND Citation Text: 627 F.3d 622 Lines: 352 Documents: Images: 0 The material accompanying this summary is subject to copyrigh

instructions. (The evolution of "dominant pur- pose" is considered at length in our opinion in United States v. Vang, supra, 128 F.3d at 1070.72.) The Fourth Circuit stated sensibly in United States v. Bennett, supra, 364 F.2d at 77, 78 n. 4, that "the `dominant motive' test seems completely inappro- priate in a