Epstein Secrets

DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1)(B), that he be permitted to intervene for

ure. If the plaintiffs move to compel production of any materials as to which the government has asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continued secrecy of matters which occurred before the two grand juries which investigated the issue of whe

UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein

l v. Costle, 561 F.2d 904, 907 (D.C.Cir. 1977). Mr. Epstein's motion is timely because it seeks intervention

overnment actors subject to the Rule 6(e) disclosure prohibition. See, e.g., United States v. Barry, 865 F.2d 1317 (D.C.Cir. 1989); United States v. Blalock, 844 F.2d 1546 (11th Cir. 1988); Eisenberg, supra. If, as in these cases, private individuals may be entitled to relief after there has been a Rule

DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1)(3), that he be permitted to intervene for

ure. If the plaintiffs move to compel production of any materials as to which the government has asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continued secrecy of matters which occurred before the two grand juries which investigated the issue of whe

UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein

s asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continue

vernment actors subject to the Rule 6(e) disclosure prohibition. See, e.g., United States v. Barry, 865 F.2d 1317 (D.C.Cir. 1989); United States v. Blalock, 844 F.2d 1546 (11th Cir. 1988); Eisenberg, supra. If, as in these cases, private individuals may be entitled to relief after there has been a Rule

DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE I AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION EFTA_R1_00004151 EFTA01731371 Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1XB), that

ure. If the plaintiffs move to compel production of any materials as to which the government has asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continued secrecy of matters which occurred before the two grand juries which investigated the issue of whe

UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION EFTA_R1_0000415

s asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continue

vernment actors subject to the Rule 6(e) disclosure prohibition. See, e.g., United States v. Barry, 865 F.2d 1317 (D.C.Cir. 1989); United States it Blalock, 844 F.2d 1546 (11th Cir. 1988); Eisenberg, supra. If, as in these cases, private individuals may be entitled to relief after there has been a Rule

case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"

REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who

n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros

ates v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. United Slates, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside

matter, the defense attorneys would suffer no harm from release of the materials. Essentially what the defense attorneys are doing is appearing as Jeffrey Epstein's "next friend" to litigate issues on his behalf. But "a 'next friend' must provide an adequate explanation -- such as inaccessibility, mental incompe

hallenge to the legality of the non-prosecution agreement therefore cannot create a sufficient interest for the defense attorneys to intervene. Only Epstein has an interest in the validity of the non-prosecution agreement, and he has deliberately chosen not to intervene in this case.2 II. THE DEFENSE AT

erns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no rec

even applies. In any event, it is obvious that grand jury secrecy only extends to matters that occurred in secret before the grand jury. See, e.g., Blalock. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

NT THIS PART OF THE VICTIMS' MOTION. In their motion (at pp. 4-6), the victims explained how the correspondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVRA case. For example, they explained that significant parts of the correspondence specifically discuss the CV

A case. For example, they explained that significant parts of the correspondence specifically discuss the CVRA and the rights of the victims in the Epstein case. The victims have therefore asked this Court to make a finding of "admissibility" regarding the correspondence, consistent with an earlier ord

orrespondence between government prosecutors and Jeffrey Epstein's counsel is highly relevant to their CVR

Statest Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock' United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside th

disputed — i.e., the Government does not contest that it deliberately concealed from the victims the existence of a non-prosecution agreement with Epstein. Accordingly, the Court should proceed on at least that basis. 1 EFTA00208024 Case 9:08-cv-80736-KAM Document 75 Entered on FLSD Docket 05:02'20

o a grand jury subpoena is simply not a "grand jury matter" to which Rule 6(e) applies. The subpoena had been issued and its existence was known to Jeffrey Epstein -- what actions he himself took in response to the issuance of the subpoena obviously were not matters occurring before the grand jury; instead, th

a had been issued and its existence was known to Jeffrey Epstein -- what actions he himself took in respo

tates.. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock'. United States, 844 F.2d 1546, 1551 (11th Cir. 1988) ("Rule 6(e)(2) only protects information revealing what has occurred, or will occur, inside t

Other Political Foes The Associated Press (11/14, Sisak, Bedayn) reported that AG Bondi ordered Manhattan U.S. Attorney Jay Clayton to investigate Jeffrey Epstein's ties to several of President Trump's political opponents after Trump publicly demanded that the Justice Department and the FBI pursue an inquiry. AG

at the Justice Department and the FBI pursue an inquiry. AG Bondi's announcement followed Trump's social-media posts calling for investigations into Epstein's "involvement and relationship" with figures including Bill Clinton, Larry Summers, and Reid Hoffman. According to the article, Trump also said he

nhattan U.S. Attorney Jay Clayton to investigate Jeffrey Epstein's ties to several of President Trump's po

), Newsweek (11/15, Higham), New York Daily News (11/15, Schladebeck), New York Post (11/15, Donlevy), New York Times (11/15, Coleman), NTD (11/15, Blalock), Patch (11/15, IJssner), People (11/15, Sheffield), Politico (11/15, Svirnovskiy), USA Today (11/15, Mansfield), and Washington Examiner. Trump Pa

S. 427, 87 S.Ct. 1 , 18 L. Ed.2d 865 (1967); Buchanan Rhodes. 885 U.S. 3, 87 S.Ct. 83, 17 .Ed.2d 9 (1966); Idlewild Bon Voyage Liquor Corp. v. Epstein, 370 U.S. 713, 82 S.Ct. 1294, 8 L.Ed2d 794 (1962). Since in this case we affirm that refusal, we need not now decide whether or not there is juri

, Gary A. Hughes, J.D, Steven D. Najarian, J.D., Jeffrey A. Schafer, J.D., and Jeffrey J. Shampo, J.D. II

Ex pane Jones County Grand Jury, First Judicial Dist., 705 So. 2d 1308 (Miss. 1997). [F1436) Kent I. Benson, 945 F.2d 372 (11th Cir. 1990. [F1437) Blalock LU.S., refill; denied, 856 F.2d 200 (11th Cr. 1988) and (distingured by, estin McDaniel, 760 F. Supp. 1563 (M.D. Ga. 1991)) and (disagreed with o