Epstein Secrets

1 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 Pottinger

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

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, 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-mail: bra

F.3d at 1081 (quoting Chaney, 470 U.S. at 831). That type of inquiry is exactly the one requested by Jane Does #1 and #2 — did the U.S. Attorney's Office for the Southern District of Florida violate the CVRA. Here, Petitioners' request should be examined with even greater caution than the average agency decision because it in

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, 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-mail: bra

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

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, 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-mail: bra

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

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney Col

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

duction 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 is convenie

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,

d States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fax: E-mail: Paul G. Cassell S.J. Quinney Col

F.3d at 1081 (quoting Chaney, 470 U.S. at 831). That type of inquiry is exactly the one requested by Jane Does #1 and #2 — did the U.S. Attorney's Office for the Southern District of Florida violate the CVRA. Here, Petitioners' request should be examined with even greater caution than the average agency decision because it in

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

d 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-mail: bra

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

and 2 v. United States, Case No. 08-80736-CIV- United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. Paul G. Cassell S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe # 1 and Jane Doe #

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