Epstein Secrets

nited States v. Mardi., 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants "is fairly easily met." United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (ND. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only "show that the specific nature of

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

s from the context involving pornography or sex crime allegations, such as the Deutsch case coming from the Eastern District several years ago, the Conway case in the Northern District of California. Again, understanding those are the allegations, the decision was made that release could be awarded o

you, your Honor. As I mentioned before, your Honor, the government has received a written statement from a victim who prefers to be referred to as Jane Doe today in order to protect her privacy. The following are the words of Jane Doe which I will read from her written statement. Jane Doe wrote: "I k

Loftus, E.F. (1998) Illusions of Memory. Proceedings of the American Philosophical Society, 142, 60-73. Loftus, E.F. (1998) Imaginary memories. In Conway, M.A., Gathercole, S.E., & Comoldi, C. (Eds) Theories of memory. Vol II. East Sussex, United Kingdom: Psychology Press Ltd. p. 135-145. Mazzoni, G.

Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu

nited States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants "is fairly easily met." United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (ND. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only "show that the specific nature of

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

nited States v. Martir, 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants "is fairly easily met." United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (ND. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only "show that the specific nature of

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

nited States v. Mardi., 782 F.2d 1141, 1144 (2d Cir. 1986). Accordingly, the statutory demand on defendants "is fairly easily met." United States v. Conway, No. 4-11-70756, 2011 WL 3421321, at *2 (ND. Cal. Aug. 3, 2011). To rebut the presumption, a defendant need only "show that the specific nature of

ther authorized or helped negotiate the resolution of the matter. See, e.g., United States' Second Supplemental Privilege Log filed as Dkt. 329-1 in Jane Doe #1 and Jane Doe #2 v. United States, No. 08-CV-80736 (S.D. Fla.) (the "CVRA litigation") (illustrating the number of prosecutors involved in the dec

s from the context involving pornography or sex crime allegations, such as the Deutsch case coming from the Eastern District several years ago, the Conway case in the Northern District of California. Again, understanding those are the allegations, the decision was made that release could be awarded o

you, your Honor. As I mentioned before, your Honor, the government has received a written statement from a victim who prefers to be referred to as Jane Doe today in order to protect her privacy. The following are the words of Jane Doe which I will read from her written statement. Jane Doe wrote: "I k

/92 K.P./S.D. v. YMCA of Greater Miami (Miami, Florida) Testified at deposition, 11/23/92 State of South Carolina v. Johnnie Kenneth Register, II (Conway, South Carolina) Testified at trial, 1/22/93 Commonwealth of Massachusetts v. Kenneth G. Seguin (Cambridge, Massachusetts) Testified at trial, 1

k, New York) [2nd Circuit Opinion: 938 F.2d 1535 (2nd Cir. 1991)] Testified at deposition, 5/13/90 Testified in court (trial or hearing), 5/14/90 Jane Doe v. Stuart Brown. M.D. (San Diego, California) Testified by deposition, 6/6/90 Carin Evans vs. Richard Benton, Ph.D. (Houston, Texas) Testified at

ce Social Sectieny No. Comity ID No. Dale of Binh Name Date of Citinduhip Die of Residency Occupation Addressor Residence Social Security No. Conway ID No. Pat of Berth b.) Agreement of LLLP EFTA00182202 NEM b.) Agreement of LLLP General Partner Ord if attacked. Appendix IL (n) r L r c

6, 09-80802, 09-81092, DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. I am an attorney for Jane Doe No. 4. 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at 350 Australian Ave. South, Suite 115, West Palm Beach, Florida. On the day before the de

vily and some were using drugs. For reasons not reflected in the re- cord, a violent altercation ensued. Fell pro- duced a kitchen knife and stabbed Conway approximately 50 times causing his death. Lee began stabbing Debra Fell and killed her with multiple wounds to the head and neck. Fell and Lee th

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