Epstein Secrets

"encompass the entire criminal investigatory process," but rather "at the very least requires the initiation of legal proceedings." P M()Chavez it Martinez, 538 U.S. 760, 766, 123 S.Ct. 1994, 155 L.Ed.2d 984 (2003). Notably, in so holding, the Court drew on longstanding tradition, citing its now nearl

n legal parlance the judicial-case connotation is undoubtedly primary." Maj. Op. at 1207. As to the term "case," even the Majority cites Chavez v. Martinez, 538 U.S. 760, 766, 123 S. Ct. 1994, 2000-01, 155 L.Ed.2d 984 (2003), which supports my conclusion that the CVRA's conferral right attaches pre- cha

pstein's conduct. After developing substantial incriminating evidence, the FBI referred the matter for prosecution to the United States Attorney's Office for the Southern District of Florida. Beginning in January 2007, and over the course of the ensuing eight *1199 months, Epstein's defense team engaged in extensive negotiations with f

rc "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (51° Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

between the ages of thirteen and seventeen to engage in prostitution, among other offenses. The case was presented to the United States Attorney's Office for the Southern District of Florida, which accepted the case for investigation. The Palm Beach County State Attorney's Office was also investigating 4 EFTA00177012 Case 9:08-cv-807

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez v. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara v. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judi

ations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. The Motio

re "merely a statement of assertion or concession made for some independent purpose," and may be controverted or explained by the party who made it. Martinez I. Bally's Louisiana, Inc., 244 F.3d 474, 476-77 (V' Cir. 2001), citing McNamara'. Miller, 269 F.2d 511, 515 (D.C. Cir. 1959). In contrast, a judic

ations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation after the undersigned retired from the United States Attorney's Office for the Southern District of Florida (the "Office"). They also falsely allege that Movant, while still employed by the Office engaged in improper conduct relating to Epstein. The Motio

e Dalton School (return date 9/29/09) 9/26/2006 Acosta, Mulvihill, Sloman, Noto, Waters, L°urie' Stefin, Atkinson, Garcia, Brown, Boscovich, Martinez Villafaila Memo regarding changes to Child Explotation Statutes in Tide 18 16 10/19/2006 Subpoena to Individual #28 (return date 10/27/06) 10/2

continued secrecy; and (5) the request is structured to cover only the needed materials. EFTA00225479 Accordingly, the United States Attorney's Office for the Southern District of Florida, including Assistant United States Attorney A. Marie Villafafia, and the Justice Department's Office of Professional Responsibility may disclose to