Epstein Secrets

with the person who was being prosecuted. 50. RFP No. 17 asks for documents concerning an investigation into the Epstein prosecution undertaken by the Justice Department's Office of Professional Responsibility (OPR) in Washington, D.C. The investigation was undertaken at the request of the victims, who asked the Justi

information about possible improper behavior during the investigation of the Epstein matter. Gov't Answers to RFA 122 (government admits that "The Justice Department's Office of Professional Responsibility and/or other Government entities have collected information about . . . other government attorney's [apart fro

tment accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the pot

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00208644 Case 9:08-cv-80736-KAM Document 225-1 Entered o

with the person who was being prosecuted. 50. RFP No. 17 asks for documents concerning an investigation into the Epstein prosecution undertaken by the Justice Department's Office of Professional Responsibility (OPR) in Washington, D.C. The investigation was undertaken at the request of the victims, who asked the Justi

information about possible improper behavior during the investigation of the Epstein matter. Gov't Answers to RFA 122 (government admits that "The Justice Department's Office of Professional Responsibility and/or other Government entities have collected information about . . . other government attorney's [apart fro

tment accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the pot

ways to reduce any such burden. DATED: June 24, 2013 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah and EFTA00615913 Case 9:08-cv-80736-KAM Document 265-1 Ent

otographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Alex Acosta. 22. The Justice Department's Office of Professional Responsibility and/or other Government entities have collected information about: (a) (b) (c) Bruce Reinhart's possible i

he Government possesses information (including telephone logs or emails) reflecting contacts between Bruce E. Reinhart and persons working at or for the Department of Justice or United States Attorney's Office that related to Jeffrey Epstein or the investigation into Jeffrey Epstein and other potential co-conspirators of

the privilege. EFTA00205113 DATED: December 1, 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFI

de: a) All documents, correspondence, and other information collected by the Office of Professional Responsibility (OPR) and any other component of the Justice Department (including the FBI) in response to the victims' letter; b) All documents, correspondence, witness statements, and other information collected as pa

tment accordingly sent various issues related to the Epstein case (and, on information and belief, issues related to Jane Doe #1 and Jane Doe #2) to the Department of Justice and to a United States Attorney's Office in another District. Please provide all documents, correspondence, and other information regarding the pot

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00205878 and Paul G. Cassell Pro Hac Vice S.J. Quinne

otographs, emails or statement(s) of other credible sources) about a personal or business relationship between Jeffrey Epstein and Alex Acosta. 22. The Justice Department's Office of Professional Responsibility and/or other Government entities have collected information about: (a) (b) (c) Bruce Reinhart's possible i

he Government possesses information (including telephone logs or emails) reflecting contacts between Bruce E. Reinhart and persons working at or for the Department of Justice or United States Attorney's Office that related to Jeffrey Epstein or the investigation into Jeffrey Epstein and other potential co-conspirators of

the privilege. EFTA00208177 DATED: December 1, 2011 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Jane Doe #2 CERTIFI

ines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adversaries." Id. at 1429. This holding makes sense, because it is ha

nt 106 Entered on FLSD Docket 10/10/2011 Page 26 of 27 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT

8-cv-80736-KAM Document 226 Entered on FLSD Docket 08/16/2013 Page 9 of 18 possessed information reflecting contacts between and persons working at the Justice Department that related to the Epstein investigation. See Government's Answers to Jane Doe #1 and Jane Doe #2's First Request for Admissions (RFA's), fi 15-17.

such a responsive document. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universi