Epstein Secrets

RANSMISSION OK TX/RX NO 2691 CONNECTION TEL 3556727 SUBADDRESS CONNECTION ID ST. TIME 09/06 20:41 USAGE T 06'34 PGS. SENT 16 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida Ave. Suite 400 West Palm Beak Florida 33401 FACSIMILE COVER SHEET TO: DENISE COFFMAN, EGO,

Attorney West Palm Beach, FL 33401-6235 • To lass1 • In of AO110 FORM ORD-227 JAILF6 Case No. 08-80736-CV-MARRA P-000188 EFTA00227568 U.S. Departn of Justice United States Attorney Southern District of Florida 500 S Australian Ave.. Suite 400 West Palm Beach. FL 334014233 (361)8204711 APPEARANCE NOTI

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

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

(1) Federal Rule of Evidence 410 or (2) a purported "common law privilege" for "plea negotiations" that the attorneys ask the Court to create under Federal Rule of Evidence 501. The defense arguments are meritless for multiple, independent reasons. With regard to Rule 410, the defense attorneys' efforts to invoke Rule 410

fied. The court will not embrace such a strained construction of the statute. 5 The government acknowledges that the USAO/SDFL has been recused by the Department of Justice for prospective responsibility of any further criminal investigation or potential prosecution of Epstein relating to his alleged sexual activities w

ed to obtain those materials in discovery in the first instance. That question must be answered by reference to Fed. R. Civ. P. 26, which refers to Federal Rule of Evidence 501, which "empower[s] the federal courts to `continue the evolutionary development of [evidentiary] privileges." Adkins v. Christie, 488 F.3d 1324, 132

EFTA00186707 U.S. Departme A- Justice U.S. Department of Justice United States Attorney Southern District of Florida Grand Jury Coordinator State Attorney's Office 15th Judicial Circuit of Florida West Palm B

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

gent parties and criminal defendants who are unable to pay such costs (28 USC 1825, Rule 17(b) Federal Rules of Criminal Procedure)" EFTA00186750 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 DELIVERY BY FACSIMILE Denise

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court fords this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

authorizing information relating to himself or herself to be released to another person. Further. pursuant to 5 U.S.C. Section $52atbl. l authorize the U.S. Department of Justice to release any and all information relating to me to: r 6 one. (\No C el s cc . Print or Type Name i declare under penalty of perjury exam the

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela

s is azthorizing information relating to himself or herself to be released to another person. Further, pursuant to S U.S.C. Set 55:2t19- t actherize the U.S. Department of Justice to release any and all information relating to me to: I declare under penalty of perjury indeed-Ara-star& Unrad States of America that the foregoing

naed materials are privileged. Specifically, the District Attorney argues that the state grand jury secrecy law creates a federal privilege under Federal Rule of Evidence 501. The Court finds this argument without merit. [8] Evidentiary privileges protect confidential communications between persons in special rela