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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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
were made limiting Epstein's criminal liability — and improperly represented people close to Epstein. During the federal investigation of Epstein, Bruce Reinhart was a senior Assistant U.S. Attorney in the U.S. Attorney's Office for the Southern District of Florida. Within months after the non-prosecution agr
we are also writing to ask for your non-opposition to Jane Doe No. 3 and Jane Doe No. 4's motion to intervene in the case. As you know, Rule 24 of the Federal Rules of Civil Procedure allows intervention on two grounds: Mandatory intervention is allowed where a putative intervenor "claims an inter relating to the . . .
-07433-RWS SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION To: David N. Rodgers, do Bruce Reinhart, McDonald Hopkins LLC, (Name of person to whom this subpoena is directed) ye Production: YOU ARE COMMANDED to produce at the time, date, and place
NTIFF'S NOTICE OF SERVICE OF RULE 45 SUBPOENA FOR DOCUMENTS UPON DAVID RODGERS (A/K/A DAVE RODGERS) PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil Procedure, Plaintiff, hereby provides Notice of Service of Subpoena upon David Rodgers (a/k/a Dave Rodgers). A copy of the Subpoena is attached to
; Jay P. Lefkowitz, PRO HAC VICE, Kirkland & Ellis, LLP, New York, NY; Martin G. Weinberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston, MA. For Bruce Reinhart, Intervenor: Bruce Reinhart, McDonald Hopkins, LLC, West Palm Beach, FL. For internal use only SDNY_GM_00059569 CONFIDENTIAL - PURSUANT TO FED. R
76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation
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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
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
ell). Id. The Court then noted: "Because the Court will allow this limited factual development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this context. The Court therefore reserves ruling on [the victims'] motion [for an order directing the Govern
ir suit by voluntary requests for interview with persons who are no longer emilearilie 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
e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic
Entities connected to both Bruce E. Reinhart and the Federal Rules of Civil

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Scarola
PERSON
Sarah Kellen
PERSONMichael J. Pike
PERSON
Kenneth Marra
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSONIsidro Manuel Garcia
PERSONSpencer Kuvin
PERSONScott Rothstein
PERSON
Salt Lake City
LOCATION
Adam D. Horowitz
PERSONMermelstein & Horowitz
ORGANIZATION
Alan Dershowitz
PERSON
Scarlett Johansson
PERSONRobert D. Critton
PERSON