Epstein Secrets

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend

the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'

ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea

a minimum, EFTA00177811 they have a "substantial case on the merits," and the "harm factors" militate in favor of granting a stay, Medal Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778 (1987)); they will be immediately and irreparably harmed by the

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); 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 (Doc.

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

ntinuing exchanges of letters and memos in which Mr. Epstein's counsel addressed the reasons why Mr. Epstein s

a minimum, EFTA00583389 they have a "substantial case on the merits," and the "harm factors" militate in favor of granting a stay, Merial Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778 (1987)); they will be immediately and irreparably harmed by the

prosecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Jeffrey Epstein through attorney-to-attorney settlement negotiations. The central issue they will raise on appeal is whether communications made during the course

UND. Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two state felony offenses and served a prison sentence and a term of community control probation. The agreement, with which he has fu

CTION Appellants Roy Black, Martin Weinberg, and Jeffrey Epstein hereby request that this Court stay the

and received settlements as the direct result of Mr. Epstein's agreement not to contest liability in those ca

appeal (or at a minimum, they have a "substantial case on the merits," and the "harm factors" militate in favor of granting a stay, Merial Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011)); they will be immediately and irreparably harmed by the disclosure of the communications at issue; the plainti

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); 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 (Doc.

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

continuing exchanges of letters and memos where Mr. Epstein's counsel addressed the reasons why Mr. Epstein s

a EFTA00584591 minimum, they have a "substantial case on the merits," and the "harm factors" militate in favor of granting a stay, Meria! Ltd. v. Cipla Ltd., 426 Fed.Appx. 915 (11th Cir. 2011), citing Hilton v. Braunskill, 481 U.S. 770, 778, 107 S.Ct. 2113, 95 L.Ed.2d 724 (1987)); they will be immediatel