Epstein Secrets

referred to as "the victims"), to enforce their rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. The U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein's sexual abuse of the victims and notified them that they were protected "victims" under the CVRA. The Offi

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle v. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication con

referred to as "the victims"), to enforce their rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. The U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein's sexual abuse of the victims and notified them that they were protected "victims" under the CVRA. The Offi

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication confi

of any certain set of facts, other than whether a charging document was ever filed against Jeffrey Epstein in the United States District Court for the Southern District of Florida. And while this Office remains willing to cooperate, cooperation does not mean agreeing to facts that are not relevant to the resolution

e Government has not provided factual material identifying who is the attorney, who is the client, and how the communications were confidential. See Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). 13. Deliberative Process Privilege Privilege Not Properly Invoked - Any deliberative process pri

this case. On December 10, 2010, co-counsel, Professor Paul Cassell of the University of Utah College of Law, and I met with the U.S. Attorney for the Southern District of Florida regarding this case in the U.S. Attorney's Office in Miami, Florida. At on that date, Professor Cassell presented a letter to the U.S. At

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privile