Epstein Secrets

his 7 restaurant chain all located within Palm Beach County. The contact with Feeney on this date was unannounced but upon introduction Feeney told Lavery he knew of Lavery's name. Feeney said he was recently told by some others that Investigator Lavery was out in the area interviewing people concerni

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 8, 2009 Re: Epstein /-/ interview Brian Feeney) File: 8577R On Friday, August 7, 2009, Investigator Paul Lavery interviewed Bria

interview with Barbara Rutledge was by cell telephone contact. Barbara Rutledge was identified by Tiffany Avery as being a friend of and suggested Lavery interview Rutledge. Investigator Lavery contacted Martie Rutledge and another daughter (possibly Carol) in the driveway at Martie's home, Her daug

GE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton / Michael Burman From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / interview Barbara and Martie Rutledge File: 8577R On Tuesday, July 28, 2009, Investigator Paul Lavery in

ger in person, but both had been out on vacation. Byron it was learned is still out and will not return to work until mid August 2009. Investigator Lavery had previously spoken with assistant management and a few employees but they did not know On this date (8-3-09) Brett Anderson was there and upon i

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / former employer, File: 8577R On Monday, August 3, 2009, Investigator Paul Lavery completed inquiry conc

e interview was conducted in person at the Avery is employed there as a receptionist and currently resides at , and her cell telephone number is Lavery was directed to Tiffany Avery by Blair Breen. (See that report). Investigator Tiffany Avery is a white female and could easily be described as "pen

EY CLIENT PRIVILEGE AND/OR THE ATTORNEY WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 4, 2009 Re: Epstein / / interview Tiffany Avery File: 8577R On Tuesday, July 28, 2009, Investigator Paul Lavery interviewed Tiff

was referring to Paul Lavery, a private investigator who had traveled to the homes of several victims. 11. A grand jury subpoena was served on Mr. Lavery at his office in Miami. Mr. Lavery hired an attorney and initially refused to respond to the subpoena. Eventually, based upon conversations between

tein is aware of that classification at this time. From the physical description of the private investigator, I knew that Banasiak was referring to Paul Lavery, a private investigator who had traveled to the homes of several victims. 11. A grand jury subpoena was served on Mr. Lavery at his office in Miami.

product immunity. I informed his attorney that he would need to file a Motion to Quash. so he backed down and we did a brief interview with Laver). Lavery stated that he did get the equipment from Epstein's house and he gave it to William Riley, another private investigator. We then subpoenaed Riley.

anything with them, and a private investigator came and took them away. Based upon his description. we determined that the private investigator was Paul Lavery. We subpoenaed Paul Lavery. who tried to assert a blanket attorney-client privilege/work product immunity. I informed his attorney that he would ne

Accordingly, I have enclosed a revised grand jury subpoena that provides, in greater detail, the list of documents requested. I have asked for Mr. Lavery to appear on June 19, 2006, so that, if you believe that you have a basis for a pre-appearance motion for protective order or motion to quash, you

June 6, 2007 VIA FACSIMILE Robert I. Targ, Esq. Diaz Reus Rolff & Targ LLP 100 S.E. Second Street, Suite 2600 Miami, FL 33131 Re: Subpoena to Paul Lavery Dear Mr. Targ: Thank you for your letter of June 4, 2007. Following receipt of your letter, I conducted some additional research regarding your bl

ti ,ation we know that the computers were removed by Paul Lavery, a private investigator, with the help of one of our targets. Now that we know that Lavery removed the computers, I would like to subpoena the computers to the grand jury. Lavery is a private investigator and is believed to have been worki

pstein's home, they found computer monitors and equipment, but no CPUs. From the continued investi ,ation we know that the computers were removed by Paul Lavery, a private investigator, with the help of one of our targets. Now that we know that Lavery removed the computers, I would like to subpoena the comp