Epstein Secrets

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ily members or their counsel; g. All police reports or complaints to law enforcement authorities filed by these individuals; h. Any submissions to the Epstein Victims' Compensation Program made by any of these individuals; i. All communications between or among these individuals, or between these individuals and counsel for any other

ch communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI,

d oral communications and other documents concerning any meetings between the Attorneys and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings th

ly paid/denied claims in favor of the Defendants." ECF No. 218, at 5. The Court should ignore these baseless allegations. M— the administrator of the Epstein Victims' Compensation Program, which ended long before this Action was filed and is unrelated to the Settlement—is not a Claims Administrator in this case, and Jane Doe 7 fails t

(2d Cir. 2005) 3 ii EFTA00145645 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Page 4 of 23 Willix v. Healthfirst, Inc., 2011 WL 754862 (E.D.N.Y. Feb. 18, 2011) 2 Wright v. Stern, 553 F. Supp. 2d 337 (S.D.N.Y.2008) 3 iii EFTA00145646 Case 1:22-cv-10019-JSR Document 256 Filed 11/02/23 Pa