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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
m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher v. United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) t
ney (or his agent) can use the attorney-client privilege to EFTA00211784 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen
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
m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te
ney (or his agent) can use the attorney-client privilege to EFTA00223000 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen
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
, Komspan & Stum 201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: Fax • www.RoyBlack.com EFTA00178998 under the teaching of Fisher v. United States, 425 U.S. 391, 398 (1976), result in compelling testimony from Mr. Epstein himself, in violation of his right against self incrimi
Florida 33131 • Phone: • Fax: • vwov.RoyBlack.com EFTA00179002 incriminating effect". United States v. Doe, 465 U.S. 605, 612 (1984); see also Fisher, 425 U.S. at 410 ("the act of producing evidence in response to a subpoena . . . has communicative aspects of its own, wholly aside from the content
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 also misstates the state charges pending against his client. The state grand jury returned a three-count indictment. Each count
from the EFTA00222987 Fifth Amendment, which "protects a person . . . again being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, the person's statement or act must be: (1) compelled; (2) t
iews of various witnesses taken during state's investigation. 2/27/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 1 8 3/2/2007 Subpoena to Thomas Rofrano (return date 3/13/07) 3/2/2007 Subpoena toJohanna Siola(return date 3/13/07) 3/2/2007 Subpoena to (return date 3/13/07) 3/2/2007 Subpoena to P
d ready to unwind the Agreement. B-10 11/30/2007 Kenneth Starr Alex Acosta Letter in response to 11/28/2007 letter to Assistant Attorney General Fisher. Outlines the history of negotiations with various counsel for Epstein illustrating how the Non-Prosecution Agreement was reached. Request to prov
views of various witnesses taken during state's investigation. 2/27/2007 Grand Jury Testimony of E. Nesbitt Kuyrkendall 18 3/2/2007 Subpoena to Thomas Rofrano (return date 3/13/07) 3/2/2007 Subpoena to Johanna Sjoberg (return date 3/13/07) 3/2/2007 Subpoena to Christina (return date 3/13/07) 3/2/2007
ready to unwind the Agreement. B I() 11/30/2007 Kenneth Starr Alex Acosta Letter in response to 11/28/2007 letter to Assistant Attorney General Fisher. Outlines the history of negotiations with various counsel for Epstein illustrating how the Non-Prosecution Agreement was reached. Request to prov
Entities connected to both Thomas Rofrano and Fisher

Jeffrey Epstein
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Alexander Acosta
PERSON
Supreme Court
ORGANIZATION
Department of Justice
ORGANIZATION
Scarlett Johansson
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Wilbur Ross
PERSON
Eric Trump
PERSON
Ken Starr
PERSONJack Goldberger
PERSON
Joe Biden
PERSONMaria Farmer
PERSON