Case 9:08-cv-80736-KAM Document 162 Entered on FLSD Docket 04/17/2012 Page 1 of 24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/ JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. / INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE 1AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Pursuant to Federal Rules ofEvidence 410 and 501, Federal Rule ofCriminal Procedure I I, and the Constitutional right to effective assistance of counsel, Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for disclosure of all the plea negotiation letters and emails between his lawyers and federal prosecutors during the criminal investigation [DE 50 at 5]. Mr. Epstein also opposes the motion of Jane Doe 1 and Jane Doe 2 to use these plea negotiations as substantive evidence in their quest to invalidate the Non-Prosecution Agreement [DE 51], as well as their motion to disseminate the plea negotiations to the media [DE 51 at 7]. Established case law as well as sound and substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr. Epstein's lawyers during plea negotiations with the government, and require that the letters and emails that Jane Doe I and Jane Doe 2 already have remain confidential. Mr. Epstein adopts all the arguments advanced by proposed intervenors Black, Weinberg, and Leficowitz in their motion to intervene and attached motion fora protective order [DE 56], as well as during the August 12, 2011 hearing. EFTA02753801