Epstein Secrets

The Privilege Claims at Issue Defendant has withheld 99 pages of emails with communications involving various combinations of Brett Jaffe, Esq. ("Jaffe"), Mark Cohen, Esq. ("Cohen"), Philip Barden ("Barden"), Ross Gow ("Gown), Brian Basham ("Basham"), and The facts that follow summarize Defendant

he hired Jaffe in 2009 to represent her in connection with a deposition. Maxwell Decl. 1 9. Though Defendant has failed to specify the end-date of Jaffe's representation, the in camera submissions demonstrate that these communications were made within the context of an ongoing attorney-client relati

foundation for the Court to apply foreign law to Defendant's claims. See Tansey v. Cochlear Ltd., No. 13-CV-4628 SJF SIL, 2014 WL 4676588, at •4 (E.D.N.Y. Sept. 18, 2014) ("the party relying on foreign law has the burden of showing such law bars production of documents." (quoting BrightEdge Techs., In

' United States, Case No. 08-80736-C1V-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Wcissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal 'Whether or not the CV RA applies is the central question in dispute in this matter because no federal criminal case

0736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 3 of 9 plea proceedings. Id., citing United States,. Ingrassia, 2005 WL 2875220 at •17 (E.D.N.Y. Sep. 7, 2005). The district court concluded, "[t]he CVRA, therefore, dots not authorize an unbridled gallop to any and all information in the gover

4.1 01 T: E: E: Pro ac we t° se i e 20 EFTA00304732 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 21 of 21 Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Ave., Ste. 2 Fort Lauderdale Florida 33301 T: E: Pro ac ice to e z e J. Stanley P

xual traveling companions. 26. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal sta

its production on April 28, 2016 and dated in a manner to attempt to justify the privilege claim. A similar undated letter was invented for Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman (FJW), P.L, and co-counsel, Paul G. Cassell, Esq. Menninger Decl., Ex. L. It states: Again, while the letter i

CIV. 1540 MN, 2013 WL 139560, at *2 (S.D.N.Y. Jan. 11, 2013) and United States v. Bouchard Transp., No. 08-CV-4490 NGG ALC, 2010 WL 1529248, at *2 (E.D.N.Y. Apr. 14, 2010). Ms. Maxwell agrees, which is precisely why she has not logged post-litigation privileged communications. Ms. Maxwell never stated,

Flexner LLP E: Pro Hoc Vice to be filed 20 EFTA00285442 Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 21 of 21 Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. T: E: Pro Hoc Vice to be filed J. Stanley Pottinger J. Stanley Pottinger PLLC 21 EFTA00285443

xual traveling companions. 26. In 2006, the Palm Beach Police Department investigation was turned over to the FBI and the United States Attorney's Office for the Southern District of Florida. The United States Attorney's Office investigated Defendant Epstein and his co-conspirators for their violations of numerous federal sta

. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal 'Whether or not the CVRA applies is the central question in dispute in this matter because no federal criminal case

United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E

mergency Petition and Petitioners' Motion seeking a finding that the CVRA was violated. The only material fact is that the United States Attorney's Office for the Southern District of Florida never filed federal °Whether or not the CVRA applies is the central question in dispute in this maser because no federal criminal case w