Epstein Secrets

take positions during the investigation and negotiation of this matter that has led to unprecedented federal overreaching. In fact. Judge I lerben Stern's states " . . Alta federal authorities inappropriately involved themselves in the investigation by the state authorities and employed highly irregu

the United States Attorney's Manual that require prior notification to Washington necessary to seek a lawyer's records). We once more requested Mr. Laurie to intervene. Despite these efforts. followed up with a subpoena liar Mr. Epstein's confidential medical records served directly on his chiropracto

e highly irregular and warrant a full review. We appreciate your willingness to consider the evidence. We respectfully request that you review Judge Stern's letter to Alan Dershowitz. faxed to you on December 7. 2007. in connection with the concerns we set forth in this submission. I. FEDF.RAL INVES

bly, after we objected to these overly broad and intrusive requests. Deputy Chief Andrew Laurie denied knowledge of Ms. Villalima's actions and Mr. Laurie commendably sought to significantly narrow the list of documents requested. In a subsequent court filing. Ms. Villafana referred to our agreement to

g the grant of summary judgment.”); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under R

deny the amendment. IL. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(2

deny the amendment. II. Discussion “The decision whether to grant leave to amend a complaint is within the sole discretion of the district court.” Laurie v. Ala. Ct. Crim. Apps., 256 F.3d 1266, 1274 (11th Cir. 2001). “The court should freely give leave when justice so requires.” Fed. R. Civ. P. 15(a)(

ying amendment where “addition of more plaintiffs .. . would not have affected the issues underlying the grant of summary judgment.”’); cf. Arthur v. Stern, 2008 WL 2620116, at *7 (S.D. Tex. 2008) (Under Rule 15, “courts have held that leave to amend to assert a claim already at issue in [another lawsuit