Epstein Secrets

nt to Local Rule 7.1(a)(3), undersigned counsel contacted counsel for Plaintiffs and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for Plaintiffs reported that they oppose th

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205046 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31 DISC

nt to Local Rule 7.1(a)(3), undersigned counsel contacted counsel for Plaintiffs and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for Plaintiffs reported that they oppose th

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). EFTA00230005 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD Docket 05/03/2011 Page 5 of 31 D

. 12. I never learned any confidential, non-public information about the Epstein matter. 13. In late December 2007, I had an "exit meeting" with Dexter Lee, the Office's ethics officer. As part of that meeting, Mr. Lee reviewed with me the Department of Justice's post-employment restrictions. Based on

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int'l Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00230040 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31

nt to Local Rule 7.1(a)(3), undersigned counsel contacted counsel for Plaintiffs and counsel for the United States. Assistant United States Attorney Dexter Lee reported that the United States does not oppose the Motion to Intervene. Bradley Edwards, Esq., counsel for Plaintiffs reported that they oppose th

the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson' Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). 3 08-80736-CV-MARRA 000759 EFTA00230583 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD Doc

r. 12. I never teamed any confidential, non-public information about the Epstein matter. 13. In late December 2007, I had an "exit meeting" with Dexter Lee, the Office's ethics officer. As part of that meeting, Mr. Lee reviewed with me the Department of Justice's post-employment restrictions. Based on

the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson.. Intl Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 08-80736-CV-MARRA 000794 EFTA00230618 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docke