Epstein Secrets

THERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, 1. UNITED STATES OF AMERICA, Defendant, ROY BLACK, et al., Intervenors. / INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER AND INCORPORATED MEMORANDUM OF LAW Intervenors Roy Black, Mar

orney for Intervenors CERTIFICATE OF SERVICE I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this 2ad day of May, 2014. /s/Rov Black Roy Black -13- EFTA00191302 Case 9:08,,80736-KAM Document 247-4 Entered on FLSD Docket 05/02/2014 Page 1 of 6 COMPOSITE EXHIBIT 4 EFTA00191303

-of the pela agreement. (Sorry 1-jual-have-a-bies-against-ptaintiffsz-atterneysel.687 Attorney's Correspondence at 157. Villafana continued to push Oeariz as the best choice, in EFTA00191269 beeause4t-weukl-redttee-publiei ne-niee4hing-about-Beft-feeafi*is-that-he4s-in-Miatni where-teheF-has-beea-al

remove these items from her demand list as evidence of Mr. Epstein's "non-conperation-. 'Ibis was only the beginning. also subpoenaed an agent of Roy Black (without following the guidelines provided in the United States Attorney's Manual that require prior notification to Washington necessary to seek a

n. Even after your Office conceded that it was inappmpriate for its attorneys to select the attorney representative. Ms. continued to lobby for Mr. Oeariz's appointment. ()n October 19. 2007, retired Judge %%3 Davis. who was appointed by the panics to select the attorney representative. informed Mr.

o remove these items from her demand list as evidence of r. .pstem's -non-cooperation". 'Ibis was only the beginning. also subpoenaed an agent of Roy Black (without following the guidelines provided in the United States Attorney's Manual that require prior notification to Washington necessary to seek a

o sett e civil claims. First. she inappropriately attempted to nominate !lambert "Hen" Oeariz for attorney representative. despite the fact that Mr. Oeariz has a longstanding relationship with friend and law school classmate of from counsel. We also learned from Mr. Ocariz turns out to he a very good

items from her demand list as evidence of Mr. Epstein's "non-cooperation". 'Ibis was only the beginning. Ms. Villafana also subpoenaed an agent of Roy Black (without Ibliowing the guidelines provided in the United States Attorney's Manual that require prior notification to Washington necessary to seek a

IJSAO conceded that it was inappropriate for its attorneys to select the attorney representative, Ms. Villafana continued to impro rly lobby for Mr. Oeariz's appointment. On October 19, 2007, retired Judge Edward B. who was appointed by the parties to select the attorney representative. informed Mr. E

ng. Mr. Epstein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one r

13. who was appointed by the parties to select the attorney representative. informe r. Pp s counsel that he received a telephone call from Mr. Oeariz directly requesting that Judge appoint him as the attorney s entative in this matter. Although it is unclear how Mr. cariz even knows that Judge