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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
itself is silent with respect to whether it applies to work product materi- als used to refresh recollection. See James Julian,' 93 F.R.D. at 145, Bank Hapoalim, 1994 WL 119575, at *5. It does appear, however as though the House Committee on the Judiciary did not intend the rule to operate in such a way t
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From: David Stem <1 To: Jeffrey Epstein <[email protected]> Subject: Fwd: ranking Date: Mon, 29 Oct 2012 18:57:22 +0000 Begin forwarded message: "Forbes Israel" ranks wealthiest Jew
From: David Stem <1 To: Jeffrey Epstein <[email protected]> Subject: Fwd: ranking D
From: David Stem <1 To: Jeffrey Epstein <[email protected]> Subject: Fwd: ra
n this year's list. Beny Steinmitz is the second richest Israeli, with $5.9 billion, followed by industrialist Steff Wertheimer, with $4.2 billion; Bank Hapoalim (TASE: POLI) and Shikun u'Binui Holdings Ltd. (TASE: SKBN) controlling shareholder Shari Arison, with $3.9 billion; Anon Milchen, with $3.8 billion;
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ners - Bios PROFESSIONAL EXPERIENCE EDUCATION Jeffrey Kaplan Partner • 25 years experience; Founded 3
tematic trading at a proprietary trading firm. • Prior to 2007, was a market maker and proprietary trader specializing in FX for JP Morgan Chase and Bank Hapoalim. • In the past several years, I have been running several automated trading strategies • My recent trading performance has averaged a 30% -45% Retu
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Entities connected to both Jeffrey Epstein and Bank Hapoalim
