Epstein Secrets

so contained my direct dial telephone number, the direct dial telephone number of the case agent, Nesbitt Kuyrkendall, and the telephone number for the Justice Department's Office for Victims of Crime. (Id.). Both Jane Doe 1 and Jane Doe 2 also received letters from the FBI's Victim-Witness Specialist, which were sent o

ocket 06/02/2017 Page 25 of 176 Exhibit 1 EFTA00799629 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 26 of 176 U.S. Department of Justice United Slates Attorney Southern District of FlOrida DELIVERY BY BAND James L. Bamberg, Esq. 250 S Australian Ave, Ste104 West Palm Beach, FL 33

15 EFTA00799620 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLED Docket 06/02/2017 Page 17 of 176 1264, 1307 (11th Cir. 2012). Likewise, Federal Rule of Criminal Procedure 6(e) requires confidentiality for persons subject to a grand jury investigation. My recommendations to opposing counsel to limit any ple

U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 July 2020 By Electronic Mail Robert Glassman

equest for Information Relating to Jeffrey Epstein Dear Mr. Glassman: I write in response to your letter dated June 8, 2020, seeking documents from the Department of Justice ("Dal") related to Jeffrey Epstein and plaintiff Jane Doe in Jane Doe v. Indyke et aL, No. 20-cv-484 (S.D.N.Y.). Your request is governed by federal

rsuant to the applicable Touhy regulations, DOJ cannot provide any documents in its possession governed by the grand jury secrecy rules set forth in Federal Rule of Criminal Procedure 6(e). See 28 U.S.C. § 16.26(b)(1). Please contact me once you have had a chance to review this letter if you would like to discuss the is

RANSMISSION OK TX/RX. NO 2683 CONNECTION TEL 6592380 SUBADDRESS CONNECTION ID ST. TIME 09/06 14:62 USAGE T 01'00 PGS. SENT 2 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile . FACSIMILE CO

counsel upon lift of stay by 11d' Circuit Box #2 P-008364 Thru P-008382 File folder entitled Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P

r, and subject to any other conditions that it directs — of a grand-jury matter: (i) preliminarily to or in connection with a judicial proceeding." Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand jury secrecy may be placed aside under certain circumstances to allow for disclosure. S

torney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obscenity Seotion (CEOS) had-agreeil-te-review-Bpstein1/2 -ehjeetiens-te-the--prepese4-plea-agFeement-that-hed-heen-reaehed with

on with the defendant sex offender and. niter he raised objections. slopped making notilleatIons.* Epstein sought 'a higher level of review' within the Department of Justice the motion says. 'A reasonable inference Irons the evidence is that Epstein used his sirlicani pol.lical and social connections to kitty the Justic

he United States are Epstein's attorneys during the plea negotiations. Epstein's attorneys intervened, arguing that Federal Rule of Evidence 410 and Federal Rule of Criminal Procedure 11 create a privilege for plea negotiations blocking release of the correspondence. They also argued that the cowl should find that the m

Attorney's Office") in order to satisfy the United States' federal interest in the investigation and prosecution of his offenses, in accordance with the Justice Department's Petite Policy. The defendant understands and acknowledges that the United States Attorney has no authority to require the State Attorney's Office to

nds that the amount of restitution owed to each victim will be determined at or before sentencing. 6. This Plea Agreement is governed, in pail, by Federal Rule of Criminal Procedure 11(c)(1)(C). The parties have agreed that the defendant's sentence imposed by the Court shall be two (2) yews' imprisonment to be followe

ttorney's Office") in order to satisfy the United States' federal interest in the investigation and prosecution of his offenses, in accordance with the Justice Department's Petite policy. Epstein understands and acknowledges that the United States Attorney has no authority to require the State Attorney's Office to abi

nds that the amount of restitution owed to each victim will be determined at or before sentencing. 6. This Plea Agreement is governed, in part, by Federal Rule of Criminal Procedure 11(e)(1)(C). The parties have agreed that the defendant's sentence imposed by the Court shall be two (2) years' imprisonment to be follow

U.S. Department of Justice United States Attorney Southern District of New York The SihioJ. Mollo Building One Saint Andrew's Plaza New York. New York 10007 November 18,

ntities; or a department, agency, or officer of any entity named above; and (B) a signature purporting to be an execution or attestation. Finally, Federal Rule of Criminal Procedure 27 permits a party to "prove an official record . . . in the same manner as in a civil action." Federal Rule of Civil Procedure 44(a)(1),

1992 (documents received by state agency in course of settlement negotiations to resolve federal lawsuit and confidential settlement agreement with U.S. Department of Justice open to inspection because federal law did not clearly require confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida

quire confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida constitution and common law in this case. In particular, Federal Rule of Criminal Procedure 6(e) does not restrict access to the NPA. Federal Rule 6(e) restrains grand jurors, court reporters, government attorneys, interpreters a

sed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the Special Responsibiliti

ssemination of these letters because they contain information from the grand jury's investigation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstei

1992 (documents received by state agency in course of settlement negotiations to resolve federal lawsuit and confidential settlement agreement with U.S. Department of Justice open to inspection because federal law did not clearly require confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida

quire confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida constitution and common law in this case. In particular, Federal Rule of Criminal Procedure 6(e) does not restrict access to the NPA. Federal Rule 6(e) restrains grand jurors, court reporters, government attorneys, interpreters a