Epstein Secrets

y, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state charges pending against his client. The state grand jury returned a three-count indictment. Each count charg

n an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

y, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state charges pending against his client. The state grand jury returned a three-count indictment. Each count charg

in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman I Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

l records including treatment notes of Mr. Epstein's treatment by a chiropractor (see Grand Jury Subpoena Duces Tecum, dated March 13, 2007, to Dr. Thomas Rofrano annexed as Exhibit "E"), and now, invasion of the defense camp by seeking records of the investigative work performed by Mr. Riley on behalf of you

s Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court

re transfer records 03/06/2007 OLY-31 Western Union wire transfer records 03/06/2007 OLY-32 JP Morgan Chase bank records 03/06/2007 OLY-33 Thomas Rofrano billing statements, record of payments, appointment books, treatment notes and correspondence 3/13/2007 Page -3- EFTA00193071 GRAND JURY SUB

g persons: Jeffrey Epstein, Sarah Kellen, Lesley Groff, Nadia Marcinkova, Adrian (Mucinska) Ross, Janusz Banasiak, Alfredo Rodriguez, Harry Beller, Emmy Tayler, Dana Bums, and Eric T. Gany. 9. Any and all document retention and/or destruction policies. Page 2 of 2 EFTA00193125 UNITED STATES DISTRICT CO