Epstein Secrets

and Jane Doe Ts Motion for Protective Order and Motion to Quash 04/1312009 MJP Review and update case law in preparation for Motion to Dismiss in B.B. and draft Notice of supplemental authority 04/13/2009 ASB Legal research case law 04/13/2009 BM Fax BB Notice of Filing to counsel; fax LM and

ceptance of Summons and Complaint; 0.30 hr $150.00 Summons and Complaint on Doe 101 v. Epstein 04/20/2009 RHB Review e-mail correspondence from M. Weinberg re: CMA reply to Motion to 0.10 hr $30.00 Dismiss 04/20/2009 RHB Review case law referenced In M. Weinberg e-mail, rule of levity 0.40 hr $12

e materials. The Government has already followed this procedure elsewhere and should do so here. See, e.g., Bates 000966-67 (materials about victim "B.B."). No Assertion of Privacy Rights by Other Victims. Several of the victims cited by the Government are represented by undersigned counsel and do no

A. Acosta, J. Sloman, R. Senior, K. Atkinson, D. Lee re Agreement; 8/15/08 email from J. Lefkowitz to A. Marie Villafana, K. Atkinson, IL Black, M. Weinberg re Agreement; 8/14/08 emails from A. Marie Villafafla to J. Lefkowitz, K. Atkinson, R. Black re interpretation of Agreement; email from J. Lefkow

y follows that the Due Process Clause requires that the state prove its case by clear and convincing evidence in a Megan's Law proceeding. B.B. v. Verniero, 119 F.3d 1077, 1111 (3d Cir. 1997), art. denial, 622 U.S. 1109 (1998) (citing Addington v. Texas, 441 U.S. 418, 427 (1979)); see also

pist whose primary residence is in the U.S. Virgin Islands and who also maintains vacation properties in New York and Florida. See A.53 (Letter of M. Weinberg of Aug. 16, 2010).1 Appellant does not live in New York, and since the commission of the Florida offense that forms the basis of this matter, he has