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ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion
orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as
d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the
ortions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and deny their motion
orneys, excepts for a few short portions by Jack Goldberger— have been redacted. The Intervenor Attorneys as
d information should be privileged under a common law plea negotiations privilege. In addition, in their initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the
portions of the correspondence written by government attorneys — all of the writings of Mr. Epstein's attorneys, excepts for a few short portions by Jack Goldberger — have been redacted. The Intervenor EFTA00205763 Attorneys ask that the Court order that the Jane Does cannot use the unredacted portions and den
torneys, excepts for a few short portions by Jack Goldberger — have been redacted. The Intervenor EFTA0020576
and information should be privileged under a common law plea negotiations privilege. In addition, in its initial briefing and at oral argument, the Intervenors argued that the communications were governed by the attorney work-product privilege. ARGUMENT A. The Petitioners Appear to Be Seeking to Use the P
; send draft to D. Indyke for review; work on Notice re J. Epstein's trial testimony; work on new dates for J. Epstein's deposition; follow up with J. Goldberger, D. Indyke and C. Pugatch re proposed new dates EFTA00799184 Client Ref: 0002 - 0001 Invoice # 1034 Date Services 07/11/18 SJL Telephone co
SJL Work on bankruptcy opening statement; work on Declaration of S. Link; work on Declaration of .1 Epstein; telephone conference with J. Epstein, J. Goldberger and D. Indyke; work on arguments for upcoming hearing; review multiple Responses filed by B. Edwards and follow up with client and D. Indyke re sa
ards, or Intervenors 07/19/18 SJL Work on preparations for upcoming two-day hearing on more than twenty motions; review Motion to Strike filed by Intervenors in Bankruptcy Court proceeding; review B. Edwards' Responses to our Motion to Amend Exhibit List and our Motion to Compel Edwards to Identify Witn
SJL Work on bankruptcy opening statement; work on Declaration of S. Link; work on Declaration of J. Epstein; telephone conference with J. Epstein, J. Goldberger and D. Indyke; work on arguments for upcoming hearing; review multiple Responses filed by B. Edwards and follow up with client and D. Indyke re sa
; send draft to D. Indyke for review; work on Notice re J. Epstein's trial testimony; work on new dates for J. Epstein's deposition; follow up with J. Goldberger, D. Indyke and C. Pugatch re proposed new dates EFTA00799205 Client Ref: 0002 - 0001 Invoice # 1034 Date Services 07/11/18 SJL Telephone co
ntervenors Services 07/19/18 SJL Work on preparations for upcoming two-day hearing on more than twenty motions; review Motion to Strike filed by Intervenors in Bankruptcy Court proceeding; review B. Edwards' Responses to our Motion to Amend Exhibit List and our Motion to Compel Edwards to Identify Witn
y Edwards and his client to attend and address the Court at sentencing if they so desired. 38. On June 30, 2008, AUSA Villafafla sent an e-mail to Jack Goldberger, criminal defense counsel for Epstein, a copy of which is attached hereto as Exhibit _.that-statedi-ti-Jaek-The FRI-Iles-reeeived--seveml-ettlis-re
cult peri- od of his life behind him. He is continuing his longstanding history of science philanthropy both here In South Florida and nationwide." Goldberger had blocked the unsealing by filing court papers asking that the documents stay scaled "to prevent a se- rious imminent threat to the fair, impartial
ed on Rule 501 on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(0 and Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the Court's ruling to the E
Mediation Confidentiality Order Page 6 Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Austral
ds, Epstein and a repr m Farmer Jaffe who has the full authority to settle without further consultation shall app at the mediation in person. The Intervenors' counsel, who shall have full authority to settle the matter without further consultation, shall appear at the mediation by telephone. FILED: PALM
Entities connected to both Jack Goldberger and Intervenors

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONLeon Black
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONSouthern District
LOCATIONRoy Black
PERSON
United States
LOCATIONMaria Farmer
PERSON
Department of Justice
ORGANIZATIONDarren Indyke
PERSON
Jay Lefkowitz
PERSON
Lesley Groff
PERSONMartin Weinberg
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION