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efta-efta00212527DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, UNITED STATES OF AMERICA, Defendant. / NOTICE OF OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epsicin during a federal criminal investigation. [DE 50 at 51. Doe 1 and Doe 2 seek to use these letters as evidence in this civil matter, and request the Court's permission to disseminate the letters to the international media [DE 511. Even though the letters are sealed and subject to a protective order issued by the Magistrate Judge in the related case 9:08-CV-80893, at least one of these letters was leaked last week to The Daily Beast, an online "omnivorous guide" to gossip and news that boasts 51 million web page views.' Some of the lawyers who represented Jeffrey Epstein during the federal criminal investigation an

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DOJ Data Set 9
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EFTA 00212527
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3
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3
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, UNITED STATES OF AMERICA, Defendant. / NOTICE OF OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epsicin during a federal criminal investigation. [DE 50 at 51. Doe 1 and Doe 2 seek to use these letters as evidence in this civil matter, and request the Court's permission to disseminate the letters to the international media [DE 511. Even though the letters are sealed and subject to a protective order issued by the Magistrate Judge in the related case 9:08-CV-80893, at least one of these letters was leaked last week to The Daily Beast, an online "omnivorous guide" to gossip and news that boasts 51 million web page views.' Some of the lawyers who represented Jeffrey Epstein during the federal criminal investigation an

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE #1 and JANE DOE #2, Plaintiffs, UNITED STATES OF AMERICA, Defendant. / NOTICE OF OBJECTION Petitioners Jane Doe 1 and Jane Doe 2 have moved for disclosure of settlement letters between the U.S. Attorney's Office and the lawyers who represented Jeffrey Epsicin during a federal criminal investigation. [DE 50 at 51. Doe 1 and Doe 2 seek to use these letters as evidence in this civil matter, and request the Court's permission to disseminate the letters to the international media [DE 511. Even though the letters are sealed and subject to a protective order issued by the Magistrate Judge in the related case 9:08-CV-80893, at least one of these letters was leaked last week to The Daily Beast, an online "omnivorous guide" to gossip and news that boasts 51 million web page views.' Some of the lawyers who represented Jeffrey Epstein during the federal criminal investigation and whose work product was included in the settlement letters, object to the release and dissemination the settlement letters. These lawyers will be filing a motion to intervene and a memorandum of law within the 14-day period provided by the Rules to respond to DE 50 and DE The Daily Beast, www.thedailybeast.conilblogs-and-stories/2011-03-25/jeffrey- epstein-how-the-billionaire-pedophile-got-offeasy/2/, last visited March 27, 2011. EFTA00212527 51, which Doe 1 and Doe 2 filed on March 21, 2011. Members of the defense team will be objecting and seeking a protective order on the grounds that the letters fall under the protections of opinion work-product of the lawyers, as well as the broad protections of Federal Rules of Evidence 410 and 408, Federal Rule of Criminal Procedure 11, and the constitutional right to effective assistance of counsel. The lawyers will also object to dissemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members two of the attorneys who represented Jeffrey Epstein during the investigation, are filing this pleading to provide notice to the Court and the parties of the intention to object to the disclosures sought by Doe 1 and Doe 2. A motion to intervene for this purpose, and a memorandum of law, will be filed no later than April 4, 2011. Attorney a member in good standing of the Massachusetts Bar, will be filing a motion for permission to appear pro hac vice in these proceedings. We certify that on March 28, 2011, we electronically filed the foregoing document with the Clerk of the Court using the CM/ECF system. 2 EFTA00212528 We also certify that a copy of the foregoing was sent via separate email to all counsel of record. Respectfully submitted, 3 EFTA00212529

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Case #9:08-CV-80893

Related Documents (6)

DOJ Data Set 11OtherUnknown

EFTA02726140

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UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I UNITED STATES DECLARATION OF BRADLEY J. EDWARDS, ESQ. I. I, Bradley J. Edwards, Esq., do hereby declare that I am a member in good standing of the Bar of the State of Florida. Along with co-counsel, I have represented Jane Doe #1 and Jane Doe #2 in civil suits against Jeffrey Epstein for sexually abusing them. I have also represented other girls who were sexually abused by Epstein. As a result of that representation, I have become familiar with many aspects of the criminal investigation against Epstein and have reviewed discovery and correspondence connected with the criminal investigation. I have also spoken to Jane Doe #1 and Jane Doe #2 at length about the criminal investigation and their involvement in it, as well enforcement (or lack their of) of their rights as crime victims in the investigation. I also represent Jane Doe #1 and Jane Doe #2 in the pen

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 013-80736-Civ-Marra/Nlatthewman JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. DECLARATION OF IN SUPPORT OF GOVERNMENT'S RESPONSE AND OPPOSITION TO PETITIONERS' MOTION FOR PARTIAL SUMMARY JUDGMENT AND CROSS-MOTION FOR SUMMARY JUDGMENT do hereby declare that I am a member in good standing of the Bar of the State of Florida. I also am admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh, and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District of Florida, the District of Minnesota, and the Northern District of California. My bar admission status in California and Minnesota is currently inactive. I am currently employed as an Assistant United States Attorney in the Southern District of Florida and was so employed during all of the events described herein. 2. I am the Assistant United States Attorne

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STATEMENT BY ALAN DERSHOWITZ

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Case 9:08-cv-80736-KAM Document 50

Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater

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EFTA Document EFTA01735410

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