From: Jeffrey Epstein <jeevacation®gmail.com>

Case 9:08-cv-80736-KAM Document 99

Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/2672011 Page 1 of 14 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON JANE DOES #1 AND #2, Plaintiffs, vs. UNITED STATES, Defendant. / ORDER THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order (DE 79).1 All motions are fully briefed and ripe for review, and the Court has heard oral arguments on all motions. The Court has carefully considered the briefing and the parties' arguments and is otherwise fully advised in the premises. The Court is awaiting supplemental brie

Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 1 of 14

Westlaw.

Westlaw. Pagel 749 F.3d 999, 24 Fla. L. Weekly Fed. C 1270 (Cite as: 749 F.3d 999) H United States Court of Appeals, Eleventh Circuit. Jane DOE NO. 1, Jane Doe No. 2, Plaintiffs-Appellees, 1. UNITED STATES of America, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13-12923. April 18, 2014. Background: Alleged minor victims of federal sex crimes brought action against the United States alleging violations of the Crime Victims' Rights Act ( CVRA) re- lated to the United States Attorney Office's execution of non-prosecution agree- ment with alleged perpetrator. After the victims moved for disclosure of corres- pondence concerning the non-prosecution agreement, the alleged perpetrator and his criminal defense attorneys intervened to assert privilege to prevent the disclos- ure of their plea negotiations. The United States District Court for the Southern District of Florida Court, No. 9:08-CV-80736-KAM, ordered disclosure. The inter- v

Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23

Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use,

Subject: RE: Activity in Case 9:08-cv-80736-ICAM Doe v. United States of America Endorsed Order

From: To: Subject: RE: Activity in Case 9:08-cv-80736-ICAM Doe v. United States of America Endorsed Order Date: Thu, 24 Mar 2016 15:38:56 +0000 Importance: Normal I should be available on April 20, and I think also on April 28, but I'm checking on the later date. That could be when I need to be in Nashville. I should be able to tell you before Monday. U From: Sent: Wednesday, March 23, 2016 12:52 PM To: Subj : : vi in se : -cv- - oe v. ni o menca n o er Hello again — Please see below. I will set up a conference line and send an email to the judge and all attorneys of record. By the way, I called to clarify whether "all counsel of record" meant only counsel for the Jane Does and us, and I was told that the judge wants all intervenors notified, as well. That means: Roy Black, Martin Weinberg, Jay Lefkowitz, Jeffrey Epstein, Palm Beach Post, and Palm Beach Daily News. Judge Marra denied Bruce Reinhart and Alan Dershowitz's motions to intervene. Assistant U.S. Attor

(USAFLS)" alMIN>

From: (USAFLS)" alMIN> To: NIEliSAFLSr alMIE>, Subject: Status of Outstanding Motions/Discovery issue Date: Fri, 06 Jan 2012 17:36:39 +0000 Importance: Normal (USAFLS)" Hi IN and There are several motions that are fully briefed but have not been decided: DE50: Petitioners' Motion for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (this was "held in abeyance" while the Court ordered "limited discovery"). DE51: Petitioners' Motion to Use Correspondence to Provide Violations of the CVRA and to Have their Unredacted Pleadings Unsealed. DE56: Motion to Intervene by Roy Black, Martin Weinberg, and Jay Lefkowitz DE93: Motion for Limited Intervention by Jeffrey Epstein The first three were all addressed by the Court at the August 12, 2011 hearing, although the Court allowed supplemental briefing after the hearing on DE56. The last of that supplemental briefing was filed on 10/31/2011. DE93 was fully briefed on 10/14/2011. The 90-day mark on D