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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
10 Page 1 of 25 Westlaw Page 1 183 F.R.D. 458, 51 Fed. R. Evid. Serv. 35 (Cite as: 183 F.R.D. 458) United States District Court, D. Maryland? Baltimore Division. NUTRAMAX LABORATORIES, INC., Plaiitiff, TWIN LABORATO,IES INC., et. al., De- fendants. No. Civ.AB-97-787. Dec. 7, 1998. In six patent infringe
American public when it comes to the FBI." The article added that Director Patel and Deputy Director Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about some of the details surrounding the Jeffrey Epstein case. I have reviewed the case. Jeffrey Epstein k
o plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about so
r Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked
r, officials suspect that he may have fled back to India. The article noted that in a 2017 statement, Special Agent Jonathan Shaffer from the FBI's Baltimore Division stated that Patel may be staying with distant relatives in the US. "Or he could have travelled through Canada back to India," Shaffer added. Missou
American public when it comes to the FBI." The article added that Director Patel and Deputy Director Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about some of the details surrounding the Jeffrey Epstein case. I have reviewed the case. Jeffrey Epstein k
o plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked about so
r Bongino plainly stated that notorious financier Jeffrey Epstein died by suicide in prison. "I was asked
r, officials suspect that he may have fled back to India. The article noted that in a 2017 statement, Special Agent Jonathan Shaffer from the FBI's Baltimore Division stated that Patel may be staying with distant relatives in the US. "Or he could have travelled through Canada back to India," Shaffer added. Missou
t it From: . (BA) (FBI) Sent: Wednesday, May 12, 2021 10:19:34 AM To: (BA) (FBI) < Subject: NY Lead Hey., I just assigned you a lead for NY's Epstein (50) case to interview a witness in Frederick County. It is due by Friday, this is my fault for not assigning it sooner I did not see it until today
e it until today. If you cannot get to it, I can either re-assign, ask Rockville to cover it, or ask for an extension. Let me know! Special Agent Baltimore Division Desk- Cell- EFTA00164261
Entities connected to both Jeffrey Epstein and Baltimore Division

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