Epstein Secrets

eriod because their allegations show they discovered their claims in 1997, if not earlier. Plaintiffs' invocation of an equitable tolling period or the New York "discovery rule" for fraud claims (i.e., CPLR § 213(8)), whichever is the case, fails because their own alleged facts and, separately, the document

) and 12(b)(6). I. PRELIMINARY STATEMENT: MULTIPLE SDNY JUDGES WARNED THE PERSON DRIVING THIS ACTION AGAINST SUCH FRIVOLOUS LAWSUITS Judges Sweet, Berman and Castel warned Steven Hoffenberg ("Hoffenberg"), whom Plaintiffs identify as the "Non-Party Affiant" (Compl. 15) and whose affidavit forms the e

ein, over the course of Many years, JEFFREY EPSTEIN, the defendant, sexually exploited and• abused dOzens of minor girld at his homes in Manhattan, New Yorke and Pain peach, Florida, among other locations. 2. ta•partiouiar, from at least in or about 2002, up to and including at least in or about200S, JE

UTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v . JEFFREY EPSTEIN, Defendant. 'INDICTMENT (18 U.S.C. 55 371, 1591(a), (b)(2). • and 2) GEOFFREY S. BERMAN United States Attorney Forefplflul 14 EFTA00164823 EXHIBIT B EFTA00164824 Date and time issued: AO93 (SDNY Rev, 01/17) Search and Seizure W

ein, over the course of Many years, JEFFREY EPSTEIN, the defendant, sexually exploited and• abused dOzens of minor girld at his homes in Manhattan, New Yorke and Pain peach, Florida, among other locations. 2. ta•partiouiar, from at least in or about 2002, up to and including at least in or about200S, JE

SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v . JEFFREY EPSTEIN, Defendant. 'INDICTMENT (18 U.S.C. §§ 371, 1591(a), (b)(2), and 2) GEOFFREY S. BERMAN 14 EFTA01648877 EXHIBIT B EFTA01648878 Date and time issued: AO93 (SDNY Rev, 01/17) Search and Seizure Warrant UNITED STAlES DISTRICT COURT

Florida, and/or the Northern District of Georgia (or FBI agents working therewith). and Exchange Commission; the Department of Homeland Security; the New York [City] Police Department; the Manhattan District Attorney's Office; the State Attorney's Office for the 15th Judicial District in and for Palm Beac

517 U.S. at 463 ("[U]nder Rule I 6(a)(2), [a defendant] may not examine Government work product in connection with his case."). Very truly yours, GEOFFREY S. BERMAN By Assistant United States Attorneys Southern District of New York Tel: EFTA00027238

a New York Times article dated November 30, 2019 concerning Jeffrey Epstein and alleged videos, and Episode 22 of The Weekly, a television series of the New York Times, concerning the same. In your letter, you cite Federal Rule of Evidence 16(a)(1)(E)(i), the Due Process Clause, Brady v. Maryland, 373 U.S. 83

we may confer further and then the matter may be raised with the Court. If you do not agree with this request, please advise us. Very truly yours, GEOFFREY S. BERMAN United States Attorney By: Assistant United States Attorneys 06.20.2018 EFTA00032754