Epstein Secrets

NDUM OF LAW IN SUPPORT OF INTERVENORS' MOTIONS FOR LEAVE TO INTERVENE AND TO MODIFY THE PROTECTIVE ORDER STEPTOE & JOHNSON LLP 1114 Avenue of the Americas New York, New York 10036 (212) 506-3900 October 5, 2017 CONFIDENTIAL - FILED UNDER SEAL EFTA00805389 TABLE OF CONTENTS PRELIMINARY STATEMENT

against the defendants in the Jane Doe Matter that she, herself, initiated prior to her appearance and production of that evidence in the Matter. Fourth, Jane Doe does not object to a modification of the Protective Order; she only takes issue with the scope of the proposed modification. Indeed, Jane

ttlement agreements or inflated settlement agreements that were being litigated with cases by RRA. One of those cases, Mr. Epstein and the rest of the United States became aware, were the cases that Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00788140 30 1 2 3 4 6 7 8 9 10 11 12 13 14 15

ough counsel based upon the uncontroverted procedural history provided by Mr. Burlington in front of the Fourth District Court of Appeal that the Fourth decided, through Judge Warner's opinion, to address the Tipsy Coachman issue, address it they did, and they did not disturb the trial court's find

gy market. Not surprisingly, most revolved around the Persian Gulf petro- EFTA00586505 18 monarchies, although there are two interesting ones for the United States: 1. Can Saudi Arabia's tradition of ultra-secretiveness survive the highly unpredictable unrest? The Saudis are so guarded that they will barely t

e and migration flows. Third is the fear that Islamist extremists will hijack the revolutions and impose a worse regime than the one they replace. Fourth is the concern that new regimes might not honor existing arrangements with Israel. Fifth is that soft bigotry that says that Arabs aren't ready for

hird and Fourth Districts have applied the litigation privilege to abuse of process claims. However, Wolfe itself, and the decisions of the Third and Fourth Districts cited in Wolfe, involved the litigation privilege as applied to claims of abuse of process by attorneys. None of the cases involved the ext

men who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr.

l master regarding handling numerous expected civil claims against Epstein. The letter reads in pertinent part, "The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special Master in the selection of an attorney to repr