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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
the ease of those docu- ments, since they were addressed to Mr. Sho- ham at HCA's address, the Court was willing to assume the insider status of Mr. Shoham in spite of RCA's failure of proof. EFTA00177875 hups://web2.wesilawoom/prinUprintstream.aspiks=WLW11.078Lvr=2.0.. Wdstlaw, Federal Rules of Ci
From: jeffrey E. <[email protected]> Sent: Sunday, March 12, 2017 12:39 PM To: Richard Kahn Subject: Fwd: follow up JE Forwarded messa•— From: Nili Priell
From: jeffrey E. <[email protected]> Sent: Sunday, March 12, 2017 12:39 PM To: Richard Kahn Subject: Fwd: follow up JE Forwarded messa•— From: Nili Priell Barak Date: Sun, Mar 12, 2017 at 8:36 AM Subject: Re:=follow up JE To: "jeffrey E." <[email protected]
To: "jeffrey E." <[email protected] <mailto:[email protected]» Account name: "Achrayut L=umit Ltd." Bank leumi le israel B.M. address: 2, Shoham=St. Ramat Gan 5251003 Israel branch: 666 SWIFT: routi=g no account no IBAN: Please =end by mail or fax <tel: thanks. ) the transfer confirma
From: jeffrey E. <[email protected]> Sent: Monday, March 13, 2017 3:13 PM To: Richard Kahn Subject: Fwd: follow up JE Forwarded messag= From: Nili Priell
From: jeffrey E. <[email protected]> Sent: Monday, March 13, 2017 3:13 PM To: Richard Kahn Subject: Fwd: follow up JE Forwarded messag= From: Nili Priell Barak <=pan dir="ltr">< > Date: Sun, Mar 12, 2017 at 8:36 AM Subject: Re:=follow up JE To: "jeffrey E." <
To: "jeffrey E." <[email protected] <mailto:[email protected]» Account name: "Achrayut L=umit Ltd." Bank leumi le israel B.M. address: 2, Shoham=St. Ramat Gan 5251003 Israel branch: 666 Please =end by mail or fa thanks. ) the transfer confirmation. On Mar 12, 2017, at 12:34 PM, jeffrey E.
Entities connected to both Jeffrey Epstein and Shoham