EFTA00230494

07/09/2008 15:15 FAX 5818059848 
USAO WPB CORFU 
Case 9:08-cv-80736-KAM Sument 48-9 Entered on FLSD Dirt 03/21/ 
a=••.••
••• 
30, 2003 
Re: ISIS 
Daer  .
U.S. Department of Justice 
Federal Bureau of invesegatior. 
FBI - Wet Palm Beach 
Suite 500 
505 South Flimsier Drive 
Weal Peen Beech, Fl. 33401 
Phone: (661) 833-7517 
Fax: (561)033-7970 
Your name was referred to the FBI's Warn Aseletarce Progrern as being a possible victim of a federal 
crime. We appreciate your assietance and cooperation white we are InvernigaIng ties case. We would like to 
make you aware of the victim servICes that may be evailabo to you and to answer any questions you may have 
regarding the criminal justice process throughout the kivestmetion. Our program is part of the FBI's Stott to 
ensure the victims are treated with respect and are provided information about their rights under federal law. 
These rights include notification of the status of the use. The enacted brochures provide Information about 
the FBI's Victim Assistance Program, resources and instructions for accessing the Victim Notification System 
(VNS). VNS is designed to provide you with information regardem the status of your case. 
Th4 case is currently under investigation. This can be a lengthy process and we request you-
continued patience while we conduct a thorough investigation. 
As a crime victim, you have the following rights under 18 Urited States Code § 3771: (1) The rght to
be reasonably protected from the accused: (2) The right to reasonable. accurate. end timely notice of any 
public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the 
=used; (3) The right net to be excluded from any such public creel proceeding, unless the court, after 
receMng clear and convincing evidence, determine; that testimony by the victim would be materialty sewed If 
the victim heard Other testimony at that proceeding; (4) The right to be reasonably heard at any public 
proceeding In the district court involving release, plea. sentencing. or any parole proceeding: (5) The 
reasonable right to confer with the attorney for the Government in the case; (6) The right to full and timely 
resttuton is provided In law; (7) The right to proceedings tree from unreasonabie delay. (e) The right to be 
treated with fairness and with respect for the victim's den ity and privacy. 
We will make our best efforts to ensure you we accorded the rights described. Most of these rights 
pertain to events occurring after the nit or ind4tment of an Individual for the crime, and it will become the 
responsIbiity of Inc prosecuting United States Attorney's Ofnee to ensure you are accorded those rights. You 
may also seek the advice of a private attorney with respect to these rights. 
The Victim Notification System (VNSI Is designed to provide you with creed information regarding the 
case es it proceeds through the canine) Nebo, system. You may obtain current information about this maner 
on the Internet at VYWW.Notify.USOOJ WV or from the VNS Cell Center at 1-866-D0J-4YOU (1486.365-
4968) (TDDiTTY: 1.868-226.4619) (International: 1.502-213.2767). In addition, you may use the Ca 
Center or Internet to update your contact information ancurx change your decision about participation in the 
notification program. if you update your Information to include a current email address, VNS win send 
information to Oral address. You will need IM following Victim Identification Number (VIM) '2074381' end 
Personal Identification Number (PIN) '1816' anytime you contact the Call Comer and the meet time you log on to 
VNS on It* Internet. In addition, the fatten/ you access the VNS Internet sde, you will be prompted to enter 
your test name (or business name) as current& contained in VNS. The name you should enter is RINI 
Q030 
08-80736-CV-MARRA 
000750 
EFTA00230574

07/09/2008 15:13 FAI 5618059846 
US60 Will CONFICif 
0031 
Ckse,:08-qv-110736-KAM Viument 48-9 Entered on FLSD Dee.1.0,3/41/?,911 PpatELlpf 
If you have additional questions which SivoNe this matter, please contact the Ace feted above. When 
you cab. please provide ine Ole number located al the top of this latter. Please remember, your participation 
in the notate/bon pan of this program is vriuntary. in order lo continuo to receive notifications. it is your 
responsibility to keep your contact informabon current 
Sincerely, 
cz6.4
1 )i LC+. 
o 
;TA) 
Twiler Smith 
Victim Species'! 
• 
70764. P-87 
08-80736-CV-MARRA 
000751 
EFTA00230575

Case 9:08-cv-80736-KAM Document 79 Entered on ['LSD Docket 05/03/2011 Page 1 of 4 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 013-80736-Civ-Marrellohnson 
JANE DOE #1 AND JANE DOE #2, 
Plaintiffs, 
I.
UNITED STATES OF AMERICA, 
Defendant. 
MOTION TO INTERVENE 
OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE I I ORDER 
Comes now, Movant Bruce E. Reinhart, pursuant to Federal Rule of Civil Procedure 
24(b), and seeks leave to intervene as a party-in-interest in this matter. Movant seeks to 
intervene to file a Motion for Sanctions based on unfounded factual and legal accusations made 
about Movant in Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act 
(the "Motion") [DE 48].1 In the context of a motion alleging that the U.S. Department of Justice 
violated Plaintiff's rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and 
gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of 
Justice regulations. Movant should be granted leave to intervene to rebut these false allegations, 
and to seek sanctions. Alternatively, the Court on its own initiative should require Plaintiffs and 
their counsel to show their compliance with Federal Rule of Civil Procedure 11. 
Without any attempt to tie the allegations to the asserted violation of the CVRA, 
Paragraphs 52 and 53 of the Motion falsely allege that Movant, a non-party to this matter, 
t Movant was not served with a copy of the pleading. Movant first saw the pleading on 
April 20, 2011. 
08-80736-CV-MARRA 
000752 
EFTA00230576

- ------- 
- 77777%. 
Case 9:08•cv-80736-KAM Document 79 Entered on FLSD Docket 05/03/2011 Page 2 of 4 
violated Florida Bar rules and Department of Justice regulations by representing employees of 
Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States 
Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege 
that Moven; while still employed by the Office engaged in improper conduct relating to Epstein. 
The Motion does not make any effort to connect these allegations to the relief it seeks. It does 
not explain how the accusations against Movant are relevant to its claims under the CVRA, nor 
does it explain how Movant's alleged conduct can be imputed to any party in the action. 
Because there is no proper purpose for these allegations, they are made in bad faith, 
unreasonably, vexatiously, and for the improper purpose of harassing Movant. 
Plaintiff has injected into this action questions of law and fact relating to Movant's 
alleged conduct. Movant now seeks to assert a claim under Fed. Rule Civ. P. 11 and 28 U.S.C. 
§1927 arising from the same questions of law and fact that Plaintiff raised. Movant's claim 
shares with the main action common questions of law and fact. See New York News, Inc.'. 
Newspaper and Mail Deliverer's Union, 139 F.R.D. 291, 293 (S.D.N.Y. 1991Xfor purposes of 
Rule 24(b), claim that falsities in pleading impugned movant's reputation created a question of 
fact in common with underlying cause of action). Therefore, the Court has discretion to permit 
intervention. CI Id (permissive intervention denied because it would unduly delay and 
prejudice imminent settlement of the original claims), aff'd sub nom New York News 
Kheel, 
972 F.2d 482, 487 (2d Cir. 1992). Here, the proposed intervention does not create a risk of 
undue delay or prejudice to the adjudication of the underlying claims. See Fed. R. Civ. P. 
24(b)(3). Movant should be permitted to intervene under Fed. R. Civ. P. 24(b)(1)(B). 
Unless Movant is permitted to intervene, he cannot remedy the false accusations in 
Paragraphs 52 and 53. The Department of Justice has responded to the Motion. It declined to 
respond on the merits to the allegations in Paragraphs 52 and 53 because they are so obviously 
2 
08-80736-CV-MARRA 
000753 
EFTA00230577

Case 9:08-cv-80736-KAM Document 79 Entered on FLSD Docket 05/03/2011 Page 3 of 4 
irrelevant to the Government's alleged violation of the CVRA. As such, Movant's interest is not 
adequately protected by the existing parties. 
Alternatively, Movant asks the Court sua sponse to issue an Order to Show Cause under 
Rule 11(c)(3)("On its own, the court may order an attorney, law firm, or party to show cause 
why conduct specifically described in the order has not violated Rule 11(b)"). This Court should 
not countenance a party making irrelevant, slanderous accusations against a non-party. On the 
face of Plaintiffs' Motion, it is clear that the allegations in Paragraphs 52 and 53 are irrelevant to 
whether the CVRA was violated, and therefore are not being presented for a proper purpose. 
The Court should require Plaintiffs and their counsel to show what legal and factual inquiry they 
undertook to comply with Rule 11(b) before making the allegations in Paragraphs 52 and 53, and 
to articulate the proper purpose for which these allegations were included in their Motion. 
As required by Fed. R. Civ. P. 24(c), attached to this motion is a proposed Motion for 
Sanctions. If leave to intervene is granted, the Motion for Sanctions which will be served on 
Plaintiffs' counsel under Fed. R. Civ. P. 5, but not filed for 21 days thereafter. See Fed. R. Civ. 
P. 11(cX2). 
Pursuant 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 the Motion to Intervene. 
Respectfully submitted, 
/s/ Bruce E. Reinhart 
BRUCE E. REINHART,P.A. 
Florida Bar # 10762 
250 S. Australian Avenue, Suite 1400 
West Palm Beach, Florida 33401 
(561) 202-6360 fax (561) 202-6976 
Breinhart@BruceReinhartLaw.com 
3 
08-80736-CV-MARRA 
000754 
EFTA00230578

Case 9:08-cv-80736-KAM Document 79 
Entered on FLSD Docket 05/03/2011 Page 4 of 4 
CERTIFICATE OF SERVICE 
I hereby certify that a true and correct copy of die foregoing Motion to Intervene or in the 
Alternative for a Sua Sponte Rule 11 Order was served on all counsel of record by CM/ECF on 
May 3, 2011. 
/s/Bruce Reinhart 
BRUCE REINHART 
4 
08-80736-CV-MARRA 
000755 
EFTA00230579

Case 9:08-ov-807313-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 1 of 31 
ATTACHMENT TO MOTION 
TO INTERVENE OR IN THE 
ALTERNATIVE FOR A SUA 
SPONTE RULE 11 ORDER 
08-80736CV-14.11A 
000756 
EFTA00230580

4 :F6nore• • • 
Case 9:08-cv-80736-KAM Document 79-1 
Entered on FLSD Docket 05/03/2011 Page 2 of 31 
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. 
BRUCE E. REINHART, 
Intervenor 
INTERVENOR'S MOTION FOR SANCTIONS 
Comes now, Bruce E. Reinhart, intervenor and party in interest (hereinafter 
"Movant"), and moves this Honorable Court to impose sanctions under Federal Rule of 
Civil Procedure 11(b) and 28 U.S.C. 1927 based on intentional or reckless false, bad 
faith, vexatious factual and legal assertions made about Movart in Paragraphs 52 and 53 
of Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the 
"Motion") [DE 481. 
BACKGROUND 
• 
The instant cause of action involves claims by Plaintiffk that Defendant violated 
the Crime Victims Rights Act (CVRA), 18 U.S.C. §3771, in its handling of a criminal 
investigation of Jeffrey Epstein ("Epstein") and others. The investigation ultimately 
resulted in a non-prosecution agreement between the United States and Epstein. On 
08-80736-CV-MARRA 
000757 
EFTA00230581

Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 3 of 31 
March 21, 2011, Plaintiffs filed their Motion.' Numbered paragraphs 1-50 of the Motion 
are a chronological review of the background of the Epstein investigation, including the 
interactions among the victims' counsel, counsel for Epstein, the Government and the 
FBI. Paragraph 51 asserts that at all relevant times it was feasible for the Government to 
provide certain notifications to Plaintiffs. 
Without attempting to make any connection to the asserted violation of the 
CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and 
Department of Justice regulations by representing Epstein's employees in civil litigation 
after Movant retired from the United States Attorney's Office for the Southern District of 
Florida ("Office"). They also falsely allege that Movant, while still employed by the 
Office engaged in improper conduct relating to Epstein. These allegations are made in 
bad faith, unreasonably, without reasonable inquiry into the law and facts, vexatiously, 
and for the improper purpose of gratuitously harassing Movant 
LEGAL STANDARDS 
Federal Rule of Criminal Procedure 11 
Federal Rule of Civil Procedure II states that a lawyer signing any pleading in 
federal court is certifying that: 
Mt° the best of the person's knowledge, information, and belief, formed 
after an inquiry reasonable under the circumstances: 
(1) it is not being presented for any improper purpose, such as to harass, 
cause unnecessary delay, or needlessly increase the cos: of litigation; 
(2) the claims, defenses, and other legal contentions are warranted by 
existing law or by a nonfrivolous argument for extending, modifying, or 
reversing existing law or for establishing new law; 
Movant was not served with a copy of the pleading. Movant first saw the 
pleading on April 20, 2011. 
2 
08-80736-CV-MARRA 
000758 
EFTA00230582

• 
47.•••••2:.• 
Case 9:08-cv-80736-RAM Document 79-1 Entered on P150 Docket 05/03/2011 Page 4 of 31 
(3) the factual contentions have evidentiary support or, if specifically so 
identified, will likely have evidentiary support after a reasonable 
opportunity for further investigation or discovery. 
Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, 
A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable 
attorney in like circumstances could believe that his actions were factually and legally 
justified." Id (citing Riccard 
Prudential Ins. Co., 307 F.3d 1277, 1294 (I1th Cir. 
2002)). Violations of Rule 11 are punishable by monetary and non-monetary sanctions 
against both the lawyer filing the pleading and the lawyer's client. Fed: R. Civ. P. 11(c). 
28 U.S.C. 61927 
Title 28, United States Cod; Section 1927 states: 
Any attorney or other person admitted to conduct cases in any court of the 
United States or any Territory thereof who so multiplies the proceedings 
in any case unreasonably and vexatiously may be required by the court to 
satisfy personally the excess costs, expense, and attorneys' fees reasonably 
incurred because of such conduct. 
To impose sanctions under § 1927, the Court must find that the attorney's conduct is 
' "'tantamount to bad faith.'" Amlong & Amiong, 500 F.3d 1230, 1239 (11th Cir. 2007) 
(quoting Avfrgan I. Hull, 932 F2d 1572, 1582 (11th Cir. 1991)). "[Tjhe attorney must 
knowingly or recklessly pursue a frivolous claim." Id at 1242. The finding of bad faith 
does not turn on "the attorney's subjective intent, but on the attorney's objective 
conduct." Id. at 1239. The standard is "whether, regardless of 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 Docket 05/03/2011 Page 5 of 31 
DISCUSSION 
Paragraphs 52 and 53 contain inflammatory claims that are false, misleading, and 
irrelevant to the relief sought in the Motion. See generally Declaration of Bruce E. 
Reinhart (attached as Exhibit 1 and incorporated by reference). They ultimately allege, 
"[Movant's) representations [of Epstein's employees) are in contravention of Justice 
Department regulations and Florida bar rules. Such representations also give, at least, the 
improper appearance that Reinhart may have attempted to curry [sic] with Epstein and 
then reap his reward through favorable representation." Plaintiff's Motion at 153. They 
do not cite to any particular bar rule or regulation that they believe was violated. They do 
not explain how the alleged conduct contributed to the Department of Justice's alleged 
violation of the CVRA. Nor do they explain how the alleged conduct is imputable to the 
Department of Justice. These otherwise slanderous accusations against a non-party are 
false. They were made in bad faith, without a factual inquiry reasonable under the 
circumstances, or elementary research into the legal basis for the allegations. 
Paragraphs 52 and 53 omit the following true facts, which Plaintiffs should have 
investigated before making their allegations: (1) Movant did not participate in any way in 
the Office's investigation of Epstein, (2) after leaving government employment, Movant 
did not represent Epstein before the Department of Justice, nor did Movant communicate 
with the Department of Justice about Epstein, and (3) Movant did not use confidential 
information obtained during his Government employment to the detriment of the United 
States. See Declaration of Bruce E. Reinhart at 1111-12, 17. 
Rather than conducting the required inquiry, Plaintiffs simply make two 
irresponsible and unsupported leaps. First, they incorrectly conclude that merely because 
4 
08-80736-CV-MARRA 
000760 
EFTA00230584

Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 6 of 31 
Movant worked in the Office at the time of the Epstein case, Movant must have been 
involved in the internal decisionmaking at the Office about Epstein. 
Second, they 
incorrectly conclude that because Nlovant later represented Epstein's employees in 
private civil litigation, Movant must have used confidential Government information 
improperly in his representation of Epstein's employees, and for his own financial gain. 
It is apparent that Plaintiffs conducted no factual inquiry to substantiate their 
accusations before making them. They never contacted Movant. On information and 
belief, they did not speak to any current or former personnel from the Office or the FBI 
who were familiar with the structure of the West Palm Beach Office or with Movant's 
role (or lack thereof) in the Epstein investigation. Had they done so, they would have 
learned that there were approximately 20 Assistant United States Attorneys in the West 
Palm Beach Office during the relevant time period. See Declaration of Bruce E. Reinhart 
at ¶10. They would have learned that Movant was not assigned to the same section as the 
prosecutor handling the Epstein matter. Id. They would have learned that Movant had a 
different chain of supervision from the prosecutor assigned to the Epstein matter. Id. 
They would have learned that Movant had no involvement in the Epstein investigation. 
See Declaration of Bruce E. Reinhart at 1111-12. 
Further, Plaintiffs did not conduct an adequate inquiry into the applicable 
Department of Justice regulations. 
As discussed below, to violate the relevant 
regulations, a former employee must appear before, or communicate with, the 
Department of Justice, about a particular matter in which the former employee 
participated personally and substantially while employed at the Department of Justice. 
See 5 C.F.R. §2641.201(a). The Motion contains approximately 50 paragraphs of a 
5 
08-80736-CV-MARRA 
000761 
EFTA00230585

---
..... 
7 . 1"
. 
Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 7 of 31 
detailed historical litany of the interactions among the parties to the Epstein matter. The 
Motion does not allege that Movant participated at all, let alone personally and 
substantially, as a government employee in the Epstein investigation. The Motion does 
not allege that that Movant subsequently appeared before, or communicated with, the 
Department of Justice about Epstein. To the contrary, the Motion alleges only that, after 
leaving the Office, Movant represented Epstein's employees in litigation with non-
Governmental third parties. Had Plaintiffs conducted rudimentary research into the 
applicable regulations, they would have known that any allegation that Movant violated 
these regulations was frivolous. 
Movam Did Not Violate Any Florida Bar Ride 
Relevant Florida Bar Rulea 
The potentially applicable Florida Bar rules are Rule 4-1.6(a) (Confidentiality of 
Information), Rule 4-1.9 (Conflict of Interest; Former Clients), and Rule 4-1.11 (Special 
Conflicts of Interest for Former and Current Government Officers and Employees). For 
purposes of these rules, the U.S. Department of Justice was Movant's client during his 
employment in the Office. Movant did not violate any of the bar rules. 
Rule 4-1.6(a) states: 
A lawyer shall not reveal information relating to representation of a client 
except as stated in subdivisions (b), (c), and (d), unless the client gives 
informed consent. 
Rule 4-1.6 was not violated because Movant did not know any confidential 
information about the Epstein matter, so none could be revealed. 
Rule 4.1.9 states: 
A lawyer who has formerly represented a client in a matter shall not 
thereafter 
6 
08-80736-CV-MARRA 
000762 
EFTA00230586

Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 8 of 31 
(a) represent another person in the same or a substantially related matter 
in which that person's interests are materially adverse to the interests, 
of the former client unless the former client gives informed consent; or 
(b) use information relating to the representation to the disadvantage of 
the former client except as these rules would permit or require with 
respect to a client or when the information has become generally 
known; or, 
(c) reveal information relating to the representation except as these rules 
would permit or require with respect to a client. 
Rule 4-1.9 was not violated because Movant never represented the United States in the 
Epstein matter. 
Rule 4-1.11 states in pertinent parts: 
(a) A lawyer who has formerly served as a public officer or employee of 
the government: 
(I) is subject to rule 4-1.9(b); and 
(2) shall not otherwise represent a client in connection with a 
matter in which the lawyer participated personally and substantially as a 
public officer or employee, unless the appropriate government agency 
gives its informed consent, confirmed in writing, to the representation. 
(c) A lawyer having information that the lawyer knows is confidential 
government information about a person acquired when the lawyer was a 
public officer or employee may not represent a private client whose 
interests are adverse to that person in a matter in which the information 
could be used to the material disadvantage of that person. As used in this 
rule, the term "confidential government information" means information 
that has been obtained under governmental authority and which, at the 
time this rule is applied, the government is prohibited by law from 
disclosing to the public or has a legal privilege not to disclose and which is 
not otherwise available to the public. 
(d) A lawyer currently serving as a public officer or employee: 
(1) is subject to rules 4-1.7 and 4-1.9; and 
7 
08-80736-CV-MARRA 
000763 
EFTA00230587

Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 9 of'31 
(2) shall not: 
(A) participate in a matter in which the lawyer participated 
personally and substantially while in private practice or 
nongovernmental employment, unless the appropriate government 
agency gives its informed consent; or 
(B) negotiate for private employment with any person who 
is involved as a party or as attorney for a party in a matter in which 
the lawyer is participating personally and substantially. 
Rule 4-1.11(a) was not violated because Movant did not participate personally and 
substantially in the Epstein matter. Rule 4-1.11(c) was not violated because Movant did 
not have any confidential Government information within the meaning of the rule, so he 
did he use any confidential Government information about a third party to the detriment 
of that third party. Rule 4-1.11(d) was not violated because Movant did not participate 
personally and substantially in the Epstein matter. 
Movant Did Not Violate Department of Justice Regulations 
Department of Justice Regulations 
The Department of Justice regulation containing post-employment restrictions, 5 
C.F.R. §2641.201, states in most pertinent part: 
(a) Basic prohibition of 18 U.S.C. 207(a)(1). No former employee shall 
knowingly, with the intent to influence, make any communication to or 
appearance before an employee of the United States on behalf of any other 
person in connection with a particular matter involving a specific party or 
parties, in which he participated personally and substantially as an employee, 
and in which the United States is a party or has a direct and substantial 
interest. 
(i) Participate: To "participate" means to take an action as an employee through 
decision, approval, disapproval, recommendation, the rendering of advice, 
investigation, or other such action, or to purposefully forbear in order to affect 
the outcome of a matter ... An employee does not participate in a matter 
8 
08-80736-CV-MARRA 
000764 
EFTA00230588

/Mr 
Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 10 of 
31 
merely because he had knowledge of its existence or because it was pending 
under his official responsibility.
Movant did not violate 5 C.F.R. §2641.201 because he did not participate personally and 
substantially in the Epstein matter as a Government employee. He did not appear before 
the United States on behalf of Epstein after leaving Government employment. He did 
not communicate with the United States on behalf of Epstein after leaving Government 
employment. 
He represented Epstein's employees in civil cases in which the 
Government was not a party. 
It is clear from the face of the regulations that Movant's representing Epstein's 
employees in civil matters not involving the Government did not violate §2641(a). In 
fact, had Plaintiffs and their counsel properly investigated the facts and law, they would 
have seen that §2641(a) would have permitted Movant to represent Epstein, himself, 
openly against the Department of Justice. Movant did not. The allegation that Movant 
violated Department of Justice mule/ions is frivolous. 
2 A comp:ete copy of this regulation is attached to this Motion as Exhibit 2. 
9 
08-80736-CV-MARRA 
000765 
EFTA00230589

Case 9:08-cv-80 736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 11 of 
31 
CONCLUSION 
The allegations in Paragraph 52 and 53 of the Motion are false, made in bad faith, 
and made without sufficient inquiry into the law and facts. They are irrelevant to whether 
the United States Attorney complied with the CVRA. Notably, the Motion does not 
attempt to tie the allegations against Movant to the alleged violation of the CVRA. The 
allegations arc included gratuitously in the Motion solely to harass Movant in a forum 
where the accusations are not legally slanderous. The allegations are made without 
reasonable pre-filing inquiry into the facts or law. This Court should issue an Order to 
Show Cause why sanctions should not be imposed under Rule II or 28 U.S.C. § 1927. 
Respectfully submitted, 
/s/ Bruce E. Reinbari 
BRUCE E. REINHART,P.A. 
Florida Bar,/ 10762 
250 S. Australian Avenue, Suite 1400 
West Palm Beach, Florida 33401 
(561) 202-6360 fax (561) 202-6976 
Breinhart®BruceReinhartLaw.com 
CERTIFICATE OF SERVICE 
1 hereby certify that a true and correct copy of the foregoing Intervenor's Motion 
For Sanctions was served on all counsel of record by CIV1/ECF on 
2011. 
/s/Bruce
BRUCE REINHART 
10 
08-80736-CV-MARRA 
000766 
EFTA00230590

Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 12 of 
31 
EXHIBIT 1 
08-80736-CV-MARRA 
000767 
EFTA00230591

1 
Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 13 of 
31 
DECLARATION OF BRUCE E. RE1NFIART 
I, Bruce E. Reinhart, make the following declaration pursuant to 28 U.S.C. §1746. 
I. 
I am a licensed attorney in solo practice as Bruce E. Reinhart, P.A. My office 
is located at 250 S. Australian Avenue, Suite 1400, West Palm Beach, Florida, 
33401. 
2. 
I am a member in good standing of the bars of the states of Florida, 
Pennsylvania, and New Jersey. I am also admitted to the practice in the 
United States District Court for the Southern District of Florida, the U.S. 
Court of Appeals for the Eleventh Circuit, the U.S. Supreme Court, and 
several other federal courts. 
3. 
I graduated from Princeton University in 1984 with a B.S.E. in civil 
engineering can laude. I graduated from the University of Pennsylvania Law 
School in 1987, can laude. I also served as an Editor of the University of 
Pennsylvania Law School. 
4. 
After graduating from law school, I served as judicial law clerk to the 
Honorable Norma L. Shapiro, Unitqd States District Judge for the Eastern 
District of Pennsylvania. 
5. 
In 1988, I began working at the Criminal Division of the United States 
Department of Justice in Washington, D.C., through the Attorney General's 
Honors Program. From 1988-1994, I worked in the Public Integrity Section 
of the Criminal Division. While working there, I received two Special 
Achievement Awards for Meritorious Acts and Service from the 
Department of Justice. 
08-80736-CV-MARRA 
000768 
EFTA00230592

Case 9:08-cv-80736-KAM Document 79-1 
Entered on FLSD Docket 05/03/2011 Page 14 of 
31 
Page 2 of 4 
6. 
While at the Public Integrity Section, I was involved in investigating and 
prosecuting people who violated federal conflict of interest and post-
employment statutes. I attended multiple training conferences where federal 
conflicts of interest laws and regulations were diccAssed. 
7. 
From in or about July 1994 to on or about May 1, 1996, I served as Senior 
Policy Advisor to the Undersecretary of the Treasury for Enforcement at the 
United States Department of the Treasury. 
In that position, I helped the 
Undersecretary, the Deputy Secretary, and the Secretary of the Treasury to 
develop law enforcement policies for U.S. Customs, ATF, Secret Service, and 
IRS Criminal Investigations. I also acted as principal staff liaison to the 
Deputy Attorney General, the FBI and the other Department of Justice law 
enforcement agencies. For my service, I was awarded the Undersecretary for 
Enforcement's Award for Exceptional Service. 
8. 
I am the former Vice Chair of the Palm Beach County Bar's Professionalism 
Committee. I am the former President of the Palm Beach County Chapter of 
the Federal Bar Association. I currently serve as an Ethics Commissioner on 
the Palm Beach County Commission on Ethics. 
9. 
From May 1, 1996 to January 1, 2008, I served as an Assistant United States 
Attorney in the Southern District of Florida, assigned to the West Palm Beach 
office. From in or about July 1998 to in or about October 2002, I was a 
Supervisory Assistant United States Attorney. From October 2002 to January 
2008, I was a non-supervisory Assistant United States Attorney handling my 
own docket of cases. 
08-80736-CV-MARRA 
000769 
EFTA00230593