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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
t=EleventhCircuit&destination... 9/26/2011 EFTA00178007 Page 1 of 27 Westlaw. 95 S.Ct. 2160 422 U.S. 225, 95 S.Ct. 2160, 45 L.Ed.2d 141, 20 Fed.R.Serv.2d 547 (Cite as: 422 U.S. 225, 95 S.O. 2160) Supreme Court of the United States Reversed. UNITED ST ES, Petitioner, Robert Lee NOBLES. No. 74-634
TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. 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 Jeff
sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use the content of the communications that memorialized ongoingse plea and settlement negot
UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO
during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D
al loyment ir. tunity practices, Banks v. Lockheed-Georgia Co., 53 . 283 .1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 ( .1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 li .1992); to academic peer reviews, Keyes
Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeff
sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non-Pr
Intervenor Jeffrey Epstein s Motion For a Protective Order And Oppo
during the criminal investigation [DE 50 at 51. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D
opportunity practices, Banks v. Lockheed-Georgia Co., 53 F.R.D. 283 (N.D.Ga.1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 (S.D.N.Y.1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 (E.D.N.Y.1992); to academic peer revie
TRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1 AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Jeff
sure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non- Pr
UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPO
during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane D
al loyment ir. tunity practices, Banks v. Lockheed-Georgia Co., 53 . 283 .1971); to accounting records, New York Stock Exchange v. Sloan, 22 Fed.R.Serv.2d (Callaghan) 500 ( .1980); to securities law, In re Crazy Eddie Securities Litigation, 792 F.Supp. 197 li .1992); to academic peer reviews, Keyes
Entities connected to both Jeffrey Epstein and R.Serv.2d
Leon Black
PERSON
United States
LOCATIONJane Doe
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Jay Lefkowitz
PERSON
Scarlett Johansson
PERSON
American Airlines
ORGANIZATION
Supreme Court
ORGANIZATIONPeterson
PERSONHerman
PERSON
Columbia University
LOCATIONthe Eleventh Circuit
ORGANIZATIONthe Northern District
LOCATIONPensacola
LOCATIONCunningham
PERSONSantobello
PERSON
the Fifth Circuit
ORGANIZATIONFederal Rule of Criminal
ORGANIZATIONSloan
PERSON