5
Shared Docs
5
Same-Page
5 / 5
Mentions
uit by voluntary requests for interview with persons who are no longer employed by the Justice Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignor
ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr
tence of the non-prosecution agreement confidential. Except as otherwise admitted above, the government denies Request No. 14. 15. Defense attorney Bruce E. Reinhart: (a) learned confidential, non-public information about the Epstein matter; UNITED STATES RESPONSE: 15. (a) The government admits that, while Bru
ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr
r suit by voluntary requests for interview with persons who are no longer emaedi g the Justice Department. For example, I have sent letters to both Bruce Reinhart and who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignored my letter
ation against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr
uit by voluntary requests for interview with persons who are no longer employed by the Justice Department. For example, I have sent letters to both Bruce Reinhart and Alex Acosta, who both have information about the Epstein case, requesting an opportunity to discuss the case with them. Both of them have ignor
Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product
tence of the non-prosecution agreement confidential. Except as otherwise admitted above, the government denies Request No. 14. 15. Defense attorney Bruce E. Reinhart: (a) learned confidential, non-public information about the Epstein matter; UNITED STATES RESPONSE: 15. (a) The government admits that, while Bru
ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr
Entities connected to both Bruce E. Reinhart and Rizzo

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Salt Lake City
LOCATION
Alan Dershowitz
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
Jay Lefkowitz
PERSON
George W. Bush
PERSON
United States
LOCATIONMartin Weinberg
PERSONMaria Farmer
PERSONRoy Black
PERSON
Virginia Giuffre
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON