EFTA00614065Set 9
2011-09-1621p6,499w
effort to invalid his non-prosecution-agreement. Yet Epstein did not move to
intervene until after the Court held a hearing on this very subject. Not only has Epstein delayed ... motion to intervene, but the circumstances of the case make it quite clear that his delay was a
deliberate tactical maneuver designed to prejudice the victims. Accordingly, the Court should ... several hearings on the case during the summer of 2008,
Epstein never sought to intervene in the action.
As the Court is also well aware, the victims ran into roadblocks
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614065.pdf
EFTA00614086Set 9
2011-09-1621p6,470w
effort to invalid his non-prosecution-agreement. Yet Epstein did not move to
intervene until after the Court held a hearing on this very subject. Not only has Epstein delayed ... motion to intervene, but the circumstances of the case make it quite clear that his delay was a
deliberate tactical maneuver designed to prejudice the victims. Accordingly, the Court should ... several hearings on the case during the summer of 2008,
Epstein never sought to intervene in the action.
As the Court is also well aware, the victims ran into roadblocks
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614086.pdf
EFTA00211439Set 9
2016-05-2225p16,498w
Martin Weinberg. Filing Fee $ 75.00. Receipt # 16719.
(ksa) (Entered: 04/05/2011)
04/07/2011 56 MOTION to Intervene of Roy Black, Martin Weinberg, and Jay Lefkowitz by Roy Black.
(Perczek, Jacqueline) (Entered: 04/07/2011 ... MOTION for Extension of Time to File Response/Reply as to 56 MOTION to Intervene of Roy
Black, Martin Weinberg, and Jay Lefkowitz Jane Doe #1 and Jane Doe #2 Unopposed ... Motion
for Extension of Time to Coordinate Filing Deadline for Responding to Motion to Intervene by
Jane Doe. (Attachments: # 1 Text of Proposed Order)(Edwards, Bradley) (Entered:
04/14/2011)
04/14/2011
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211439.pdf
EFTA00209211Set 9
2008-07-0724p8,645w
Martin Weinberg. Filing Fee $ 75.00. Receipt # 16719. (ksa) (Entered:
04/05/2011)
04/07/2011 5_¢ MOTION to Intervene ofRoy Black Martin Weinberg, andJay
LeJkowitz by Roy Black. (Perczek, Jacqueline) (Entered: 04/07/2011)
04/07/2011 ... MOTION for Extension of Time to File Response/Reply as to a
MOTION to Intervene of Roy Black Martin Weinberg, and Jay
LeJkowitz Jane Doe #1 and Jane Doe #2 Unopposed ... Motion for
Extension of Time to Coordinate Filing Deadline for Responding to
Motion to Intervene by Jane Doe. (Attachments: # .1 Text of Proposed
OrderXEdwards, Bradley) (Entered: 04/14/2011)
04/14/2011 0 MOTION
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209211.pdf
EFTA00207976Set 9
2011-05-028p2,184w
UNITED STATES
JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF
ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ
COME NOW Jane Doe #1 and Jane ... Black, Martin Weinberg,
and Jay Leflcowitz (hereinafter referred to as "defense attorneys") to intervene in this case under
Fed. R. Civ. P. 24(a) (DE #56).
The motion to intervene ... Their effort to relitigate these issues is simply untimely. The defense
attorneys' motion to intervene should accordingly be denied.
EFTA00207976
Case 9:08-cv-80736-KAM Document 78 Entered
https://www.justice.gov/epstein/files/DataSet%209/EFTA00207976.pdf
EFTA01098037Set 9
2011-10-1421p6,534w
LIMITED INTERVENTION IS TIMELY
The plaintiffs argue that Mr. Epstein's motion to intervene is a year late because when the
damages case settled in July 2010, the plaintiffs informed ... Docket 10/14/2011 Page 4 of 21
They also contend that Mr. Epstein needed to intervene in July 2010 because the settlement
agreement states that "Jane Doe 1 and Jane ... Wholesale Elec. Co., 922 F.2d 92, 97 (2d Cir.
1990) (emphasis added). To intervene under Rule 24, "a nonparty must have a `direct,' substantial,'
and 'legally protectable' interest
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098037.pdf
EFTA01098293Set 9
2011-05-028p2,319w
UNITED STATES
JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF
ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ
COME NOW Jane Doe #1 and Jane ... Black, Martin Weinberg,
and Jay Leflcowitz (hereinafter referred to as "defense attorneys") to intervene in this case under
Fed. R. Civ. P. 24(a) (DE #56).
The motion to intervene ... Their effort to relitigate these issues is simply untimely. The defense
attorneys' motion to intervene should accordingly be denied.
EFTA01098293
Case 9:08-cv-80736-KAM Document 78 Entered
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098293.pdf
EFTA01098365Set 9
2011-09-029p2,946w
Epstein pursuant to Federal Rules of Civil Procedure 24(a) and
24(b) to intervene for the limited purpose of seeking a protective order and responding to the
motions ... ability to protect [his]
interest . ." FED. R. Civ. P. 24(a). Unless allowed to intervene, Mr. Epstein could suffer the
injustice of having his privilege and confidentiality claims erased without ... ruling that colorable claims of privilege
are a textbook example of the right to intervene as of right); Appeal of Hughes, 633 F.2d 282, 286
(3d Cir. 1980) ("The governing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098365.pdf
EFTA01191873Set 9
2015-01-2140p13,998w
opposition to Mr. Dershowitz's motion
for limited intervention (DE 282). Dershowitz moves to intervene to strike a proffer made by
Jane Doe No. 3 of facts that support ... interest in this Crime Victims'
Rights Act (CVRA) action that would entitle him to intervene as of right under Fed. R. Civ. P.
24(a). Nor has he nrt Rule ... unprofessional, disbarable
lawyers." Id. On January 5, 2015, Dershowitz filed the pending motion to intervene. DE 282.
DISCUSSION
Dershowitz's motion to intervene relies
https://www.justice.gov/epstein/files/DataSet%209/EFTA01191873.pdf
EFTA00211533Set 9
2016-04-2210p2,996w
Page 2 of 10
2008, a number of individuals and entities have sought to intervene pursuant to Fed. R. Civ. P. 24.1
For purposes of this memorandum, those intervening parties ... number of motions and rulings. Thus, all intervenors filed their motions to
intervene pursuant to Fed. R. Civ. P. 24.
2
EFTA00211534
Case 9:08-cv-80736-KAM Document ... attached certain documents
disclosed in discovery (DE305). The district court granted the motion to intervene, considered
the newspapers' arguments, and denied the motion for protective order (DE326). Thus, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211533.pdf
EFTA00211513Set 9
2016-03-2811p2,895w
suit in
2008, a number of individuals and entities have sought to intervene pursuant to Fed. R. Civ. P.
EFTA00211513
24.1 For purposes of this memorandum, those parties will ... number of motions and rulings. Thus, all intervenors filed their motions to
intervene pursuant to Fed. R. Civ. P. 24.
2
EFTA00211514
B. Group 2: The Palm Beach Newspapers ... attached certain documents
disclosed in discovery (DE305). The district court granted the motion to intervene, considered
the newspapers' arguments, and denied the motion for protective order (DE326). Thus, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211513.pdf
EFTA00211680Set 9
2016-03-2810p2,831w
suit in 2008, a
number of individuals and entities have sought to intervene pursuant to Fed. R. Civ. P. 24.E For
As will be explained below, the Eleventh Circuit ... number of motions and rulings. Thus, all intervenors filed their motions to
intervene pursuant to Fed. R. Civ. P. 24.
2
EFTA00211681
These entities moved for limited intervention in order ... attached certain documents
disclosed in discovery (DE305). The district court granted the motion to intervene, considered
the newspapers' arguments, and denied the motion for protective order (DE326). Thus, there
https://www.justice.gov/epstein/files/DataSet%209/EFTA00211680.pdf
EFTA00583886Set 9
2013-07-264p1,444w
INTERVENTION
In their Response, plaintiffs first contend that Mr. Epstein's limited motion to intervene is
not timely because they first filed their discovery requests more than a year ... Plaintiffs state
that they did not object to Mr. Epstein's prospective motion to intervene at the remedy stage
because "the issue had not yet been subject to any litigation ... same is true,
however, with respect to this limited motion to intervene.
EFTA00583886
Contrary to plaintiffs' argument, Response at 4, Epstein did not wait long at all to file
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583886.pdf
EFTA01102347Set 9
2011-11-045p1,183w
LEGAL FEES - RESEARCH AND WORK ON REPLY TO MOTION TO
INTERVENE: E-MAILS WITH RB CONCERNING REID WEINGARTEN. 6.10 3,507.50
P/L PARALEGAL FEES - WORK RE: CASE LAW FROM WESTLAW ... OFFICE
AND ATTEND MEETING; WORK WITH RB ON INTRODUCTION TO
REPLY TO MOTION TO INTERVENE. 2.70 1,552.50
10/06/2011
JP LEGAL FEES - E-MAILS AND CALL WITH DARREN INDYKE
CONCERNING ... 10/07/2011
JP LEGAL FEES - RESEARCH AND READ MATERIALS ON MOTION TO
INTERVENE; START WORKING ON DRAFT REPLY. 6.50 3,737.50
P/L PARALEGAL FEES - RESEARCH FARMER JAFFEE FACEBOOK PAGE
AND READ
https://www.justice.gov/epstein/files/DataSet%209/EFTA01102347.pdf
EFTA01081198Set 9
2011-09-026p1,429w
untimely and not
factually supported.
BACKGROUND
As the Court will recall, Epstein initially delayed intervening in this case but, more
recently, has filed three separate motions for "limited" intervention ... three different topics.
Several years ago, Epstein sent in defense attorneys to intervene regarding certain
correspondence regarding the non-prosecution agreement. The victims objected at that time to
his attempt ... fray later. They will accordingly oppose any later —
untimely — effort on his part to intervene in this suit. DE 78 at 4 n.2.
Epstein first sought limited intervention back
https://www.justice.gov/epstein/files/DataSet%209/EFTA01081198.pdf
EFTA01111839Set 9
2011-09-2627p6,085w
OUTCOME: Motion granted in part and denied in part.
CORE TERMS: crime victims, intervene, formal charge,
underway, confer, discovery, appearance, pre-charge,
attach, arrest, best efforts, accusation—, notified,
directing, disclose ... iiN/0+ Under Fed. R. Civ. P. 24(b), the court may
permit anyone to intervene who has a claim or
defense that shares with the main action a
common question ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA01111839.pdf