Epstein Secrets

U.S. Department of Justice United States Attorney Southern District of New York Tht Sill Ill .1 Molt, Budding October 7, 2020 VIA ECF The Honorable Alison J. Nathan Unit

States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros

hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.5 In particular, during the course of its in

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,

States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros

hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,

States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros

hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 October 7,

States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros

hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.' In particular, during the course of its in

Case 1:20-cr-00330-AJN Document 63 Filed 10/07/20 Page 1 of 8 U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mob Building One Saint Andrew's Plaza New York. New York 10007 October 7, 20

States v. Quinn, 445 F.2d 940, 944 (2d Cir. 1971) (declining to impute knowledge of prosecutor in Florida to prosecutor in New York and noting that the "Department of Justice alone has thousands of employees"). The imposition of such "an unlimited duty on a prosecutor to inquire of other offices not working with the pros

hat warrant disclosure in this case. Fifth, internal Department of Justice emails relating to the prior Florida Investigation have been gathered by the Department of Justice's Office of Professional Responsibility ("OPR"), as part of its unrelated investigation into the resolution of the prior Florida Investigation.5 In particular, during the course of its in

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

cipation of either in the instant litigation. ° The Government asserts that the work-product doctrine applies to documents prepared by attorneys in the Department of Justice's Office of Professional Responsibility (OPR) in response to Petitioners' counsel's request for an investigation into the Government's handling of the Epstein case. (DE 216-1 at 12-14). A

atypical. The result was a one-off agreement that deviated in several material respects from, and bore little resemblance to, a standard agreement. The Department of Justice's OPR, after investigating Acosta's handling of the Epstein case, characterized the NPA as a "unique resolution." Exh. B (Dep't of Justice, Office of

is understandable that the current regime may wish the government had not entered into the NPA, or that it had negotiated different terms. Indeed, the Department of Justice's Office of Professional Responsibility ("OPR") found that Acosta exercised "poor judgment" and "agreed to several unusual and problematic terms in the NPA," which OPR characterized as a

atypical. The result was I one-off agreement that deviated in several material respects from, and bore little resemblance to, I standard agreement. The Department of Justice's OPR, after investigating Acosta's handling of the Epstein case, characterized the NPA as I "unique resolution." Exh. B (Dep't of Justice, Office

is understandable that the current regime may wish the government had not entered into the NPA, or that it had negotiated different terms. Indeed, the Department of Justice's Office of Professional Responsibility ("OPR") found that Acosta exercised "poor judgment" and "agreed to several unusual and problematic terms in the NPA," which OPR characterized as I