Epstein Secrets

m the prosecutor goes hand-in-hand with the lawyer's additional duty to "make suitable inquiry" to determine whether valid defenses exist. Jones v. Cunningham, 313 F.2d 347 (4th Cir. I 963) ("Of course, it is not for a lawyer to fabricate defenses, but he does have an affirmative obligation to make suitabl

ult in a disposition of the charges in the next several days." [CVRA Petition, DE 1, 13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive timely notice of relevant cou

ntiffs MOTION Jane Doe #1 and Jane Doe #2's Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence Jane Doe #1 and Jane Doe &filed by United States of America. (Lee, Dexter) (Entered: 05/30/2011) 06/17/2011 fd Notice of Supplemental Authority ma& Plaintiffs MOTION for Sum

om the prosecutor goes hand-in-hand with the lawyer s additional duty to make suitable inquiry to determine whether valid defenses exist. Jones v. Cunningham, 313 F.2d 347 (4th Cir.1963) ( Of course, it is not for a lawyer to fabricate defenses, but he does have an affirmative obligation to make suitable

Intervenor Jeffrey Epstein s Motion For a Protective Order And Opposition to Motions of Jane Doe 1 And Jane Doe 2 For Production, Use, And Disclosure Of Plea Negotiations Jeffrey Epstein opposes the motion of Jane Doe 1 and Jane Doe 2 for dislcosure of all the

er multiple times without intervention. FN25. Although Fell summarily al- leges Fifth and Eighth Amendment violations related to the admission of Cunningham's testimony, he of- fers no supporting arguments. "Issues not sufficiently argued in the briefs are considered waived and normally will n be a

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

ein? 15 A. Directly across the street. 16 Q. Do you know what that person's name is who 17 owns that house? 18 A. Cunningham, last name is Cunningham, I think. 19 Q. Okay. And have you ever met that person 20 before? 21 A. No. 22 Q. Do you know of any occasion when that 23 person, Mr.

15 On behalf of the Defendant, Jeffrey Epstein and the Witness: 16 17 JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY GOLDBERGER & WEISS, P.A. 18 and Jane Doe: On behalf of the Plaintiff Jane Does No.'s 1 through 8. STUART MERMELSTEIN, ESQUIRE MERMELSTEIN & HOROWITZ, P.A. 20 21 22 23 24 25 (561)

“absence of records” response does not mean that records do not exist. It simply means that in the course of the search, no records were found. See Cunningham v. U.S. Dept. of Justice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (court reasoning that “t]he adequacy of a search is measured by a standard of reasonab

J. EDWARDS, and CASE NO. CACE 15-000072 PAUL G. CASSELL, Plaintiffs. Vv, ALAN DERSHOWITZ. Defendant, - ORDER ON BOIES, SCHILLER & FLEXNER LLP AND JANE DOE NO, 3’s MOTIONS TO QUASH SUBPOENAS OR FOR PROTECTIVE ORDER This Cause comes belore the Court on November 2, 2015 upon Boies, Schiller & Flexner L1P’