Epstein Secrets

, NY, USA 10020 (212) 489-8230 Fax: (212) 489-8340 Email:[email protected] FOR THE Respondent Laura R. Handman [LEAD ATTORNEY:ATTORNEY TO] Davis, Wright, Tremaine, LLP(DC) 1919 Pennsylvania Ave., Nw Suite 200 Washington, DC, USA 20006-3402 202 508-6600 X6624 Fax: 202 508-6699 Email:Laurahandman@dwt

GM_00060324 CONFIDENTIAL - PURSUANT TO FED. R.QQN(F IDENTIAL DB-SONY-0023148 EFTA_00 170862 EFTA01297311 Page 2 Giuffre V. Maxwell 1:15cv7433 SOUTHERN DISTRICT OF NEW YORK (Foley Square - NYC) V. Maxwell PLAINTIFF: DEFENDANT: Ghislaine Maxwell (Terminated 5/25/2017) Applicant: John Stanley Pottinger In

e was pending, and therefore before a final judgment was issued, the Indictment must be dismissed under the rule of abatement. See United States v. Wright, 160 F.3d 905, 908 (2d Cir. 1998). EFTA00104850 Case 1:19-cr-00490-RMB Document 47-1 Filed 08/19/19 Page 2 of 2 5. Accordingly, I recommend tha

Case 1:19-cr-00490-RMB Document 47 Filed 08/19/19 Page 1 of 1 U.S. Department of Justice United States Attorney Southern District of New York The Slivio.l. Mollo Building One Saint Andrew's Pike New York. New York 10007 August 19, 2019 VIA ECF The Honorable Richard M. Berm

e was pending, and therefore before a final judgment was issued, the Indictment must be dismissed under the rule of abatement. See United States v. Wright, 160 F.3d 905, 908 (2d Cir. 1998). EFTA00040575 Case 1:19-cr-00490-RMB Document 47-1 Filed 08/19/19 Page 2 of 2 5. Accordingly, I recommend tha

k, New York August 19, 2019 SO ORDERED: Dated: New York, New York August , 2019 .16 - 7/4,i7r/v\ GEOFFREY S.: BERMAN United States Attorney Southern District of New York Hon. Richard M. Berman United States District Judge Southern District of New York 2 EFTA00040576

ation from other cases as possible solely to impermissibly inflame the jury and appeal to the jury's emotions, or solely to prove bad character. See Wright v. State, 3 EFTA00793361 19 So. 3d 277 (Ha. 2009); Byrd v. BT Foods, Inc., 26 So. 3d 600 (Ha. 4th DCA 2009). "If the introduction of the evidenc

ions involved Edwards' three clients as follows: 6. and 16. Jane Doe No. 2 v. Jeffrey Epstein, Consolidated Action, United States District Court, Southern District of Florida, Case No. 08-CV-80119 [as to Edwards' representation only] 13. E.W. v. Jeffrey Epstein, 15th Judicial Circuit Court, Palm Beach Count

L. Weekly D1540 and the like committed during judicial proceedings are left to the discipline of the courts, the bar association, and the state," Wright, 446 So.2d at 1164, other tortious conduct occurring during litigation is equally susceptible to that same discipline. Levitt, 639 So.2d at 608

y litigation ultimately was settled. Ferrell, who was dissatisfied with the outcome, sued his partners in the United States District Court for the Southern District of Florida ("the Federal case"). Ferrell's New York counsel retained the appellees, two Miami attorneys and their law firm (the "Miami Lawyers"), t

o. 2d 562 (Fla. 5th DCA 1993)). As Defendants point out, there muse be an "actionable underlying tort or wrong" for an actionable conspiracy claim. Wright, Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984). 5 EFTA00234428 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18.2008 Page 6

ed on FLSD Docket 08'18'2008 Page 11 of 11 SERVICE LIST Doe'. Epstein, et. al. CASE NO: 08.80804-Civ-MARRA/JOHNSON United States District Court, Southern District of Florida Guy Alan Lewis, Esq. Email: [email protected] Lewis Tein 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Phone: (305) 442-110

ingle viable cause of action against 1. The plaintiff has not asserted a cause of action against for civil conspiracy.. The plaintiff, citing to Wright Yurko, 446 So. 2d 1162, 1165 (Fla. 5th DCA 1984), concedes that "there muse [sic] be an `actionable underlying tort or wrong' for an actionable co

CM/ECF - Live natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Mag

at's the phrase of all the cases reported. What facts and circumstances were known to Mr. Epstein when he filed his malicious prosecution. And the Wright versus Yorco (phonetic) case. We haven't talking about it, but -- THE COURT: I'm familiar with it. MS. ROCKENBACH: I'm sure, Your Honor. -- both

rify that point, if I could. THE COURT: Sure. MR. SCAROLA: The non-prosecution agreement is an agreement with the U.S. Attorney's office for the Southern District of Florida. It extends immunity to Mr. Epstein and his unnamed co-conspirators DRAFT ONLY !!!! NOT PROOFREAD EFTA00792918 109 1 2 3 4 5 6