Epstein Secrets

ting allegations against Epstein at that time, any work product protection was necessarily lost. DE 188 at 6 (citing, inter alia, United States v. Massachusetts Institute of Technology, 129 F.3d 681 (1st Cir. 1997). Numerous cases have reached the same conclusion as the District Court in similar circumstancesr I Exhibit B, at 35-3

With Regard to Sealed Documents, Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), respectfully submits the attached Opinion in the case of Jane Doe No. 1 v. United States, 749 F.3d 999 (11th Cir. 2014), attached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that cas

Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Limited Intervenor Co-Counsel for L.M., E.W. and Jane Doe 6 EFTA00806658

ns of the ACM 37, No. 7, 107-116 (1994). Accepted for publication May 17, 2002. J. McCarthy Stanford University Stanford, California M. Minsky Massachusetts Institute of Technology Cambridge, Massachusetts A. Sloman University of Birmingham Birmingham, UK L. Gong IBM Research Division Hawthorne, New York T. Lau IBM Research Divisi

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

Harvard University; Penn State University; Lenox Hill Hospital (New York); the Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts Institute of Technology; Case Western Reserve University; and Harvard Medical School's Institute for Music and Brain Science. Moreover, Mr. Epstein has sponsored and chair

t there, in facts far different from ose presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in Prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

Harvard University; Penn State University; Lenox Hill Hospital (New York); the Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts Institute of Technology; Case Western Reserve University; and Harvard Medical School's Institute for Music and Brain Science. Moreover, Mr. Epstein has sponsored and chair

court in Doe'. Epstein, No. 9:08- cv-80I19-KAM (S.D. Fla.). Brunel's attorney asked counsel for Jane Doe to postpone the scheduled deposition date. Jane Doe's counsel agreed, and then Brunel's attorney cancelled the rescheduled deposition date. Brunel's counsel represented that Brunel was outside the count

as RIII I 144-041919400 - in rt . nests as Eli NY 09/24 70.99 DOS-0 419401 - 62 TOC•Thit NA, IFIII wr 09/26 10.99 KS-0923104RO 16- Mit= ISIR EY 09/26 127.05 1,00-001312,904020- TUCK= MR WY EFTA00075579 1 First Bea ACCOUNT ti Thies 2 OTEMXRAIT AMC MI= r Fee SCRINCIXP r

2019 Complaint filed on August 20.2019 Complaint Red on August 20, 2019 Complaint filed on August 20.20W EFTA00075575 Civil Claims - lawsuits Jane Doc v. Darren K. Indyke and Richard I). Kahn, in their capacities n the executors of the Estate of Jeffrey It Epstein, Case No. 1:19-ev-08673 (S.I).N.Y)

Harvard University; Penn State University; Lenox Hill Hospital (New York); the Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts Institute of Technology; Case Western Reserve University; and Harvard Medical School's Institute for Music and Brain Science. Moreover, Mr. Epstein has sponsored and chair

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

Harvard University; Penn State University; Lenox Hill Hospital (New York); the Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts Institute of Technology; Case Western Reserve University; and Harvard Medical School's Institute for Music and Brain Science. Moreover, Mr. Epstein has sponsored and chair

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in Prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

ns of the ACM 37, No. 7, 107-116 (1994). Accepted for publication May 17, 2002. J. McCarthy Stanford University Stanford, California M. Minsky Massachusetts Institute of Technology Cambridge, Massachusetts A. Sloman University of Birmingham Birmingham, UK L. Gong IBM Research Division Hawthorne, New York T. Lau IBM Research Divisi

there, in facts far different from those presented here, the defendant "admitted using both a cellular telephone and a land-line telephone to entice Jane Doc to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones

Harvard University; Penn tate University; Lenox Hill Hospital (New York); the Biomedical Research and Education Foundation; the Santa Fe Institute; Massachusetts Institute of Technology; Case Western Reserve University; and Harvard Medical School's Institute for Music and Brain Science. Moreover, Mr. Epstein has sponsored and chair

there, in facts far different from those presented here, the defendant admitted using both a cellular telephone and a land-line telephone to entice Jane Doe to engage in prostitution" (emphasis added). That admission makes Evans no precedent for a prosecution here, since there is no evidence the phones