Epstein Secrets

tness an individual ("Employee-1") who worked for Jeffrey Epstein immediately 35 EFTA00088837 followin

osed testimony concerns the experience of manipulated and coerced victims, rather than the intentions of perpetrators. 19 EFTA00088821 return to Epstein's home for sexual abuse, or why some occasionally expressed affection for the defendant and Epstein. Although Dr. will not testify about these spe

consideration of the Court's pretrial order denying the defense's motion to strike Minor Victim-3 from the Indictment. Evidence of the defendant and Jeffrey Epstein's abuse of Minor Victim-3 is direct evidence of the offense charged in the Indictment, including the overt acts in the Indictment that pertain to Mino

elationship between the defendant and Epstein. For instance, to the extent the defense at trial argues that the defendant was merely an employee of Epstein's, this photograph is evidence to the contrary. Sixth, the defense argues that Government Exhibit 606 lacks evidentiary foundation, is hearsay, and i

f identification" by showing a person in that position even a single photograph, much less a photo array or photo book. See, e.g., United States v. Hardy, No. 10 Cr. 1123 (JSR), 2011 WL 7782582 (S.D.N.Y. Jan. 25, 2011) ("Displaying a confirmatory photograph of a person the witness has indicated that

approximately 1:15 pm, I received a call from lawyer Jeff Herman. Herman told me that he was planning to file a civil lawsuit the next week against Jeffrey Epstein. lie said that his clients are frustrated with the lack of progress of the state's investigation and wanted to know whether the USAO could file crim

have raised ethical concerns regarding my involvement in his potential prosecution in the Southern District of Florida. Upon information and belief, Epstein has notified Assistant Attorney General Alice Fisher and/or her staff that I have an actual and/or perceived conflict of interest because two of Ep

ave learned that lawyers for an individual named Jeffrey Epstein have raised ethical concerns regarding my

ng the current investigation and/or disciplined. Mr. Epstein is represented by Jay Lelkowitz, Esq. and Dean K

name to Lefkowitz. I told him that he was mutual friends with two people whom I respected. I also told Leflcowitz that Ocariz worked at the Shook, Hardy, and Bacon finn, and that he had worked with Guy Lewis, another of Epstein's attorneys. Later, Leflcowitz called me and said that he had checked on

to anyone else. The Agreed Order Cancelling Hearing provides, in its entirety: The Motion for Relief From Amended Order (D.E. #1068) and to Compel Jeffrey Epstein to Pay for the Production of All Documents in Response to his Requests filed by Interested Party Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,

ions" (id. at p. 17) or a finding of criminal contempt "as may be appropriate" and monetary sanctions of $25,000 for each of the intervenors against Epstein for any noncompliance with the order at issue, for which amounts "Epstein [be] permitted to seek reimbursement from any of his attorneys who may ha

E OF AN ORDER TO SHOW CAUSE WHY FOWLER WHITE AND JEFFREY EPSTEIN SHOULD NOT BE HELD IN CONTEMPT OF COURT,

in its files, having provided all hard files to Mr. Epstein's current counsel, Scott Link. Movants' Motions

the public interest and (2) whether the contemnor may control the extent of the award."' In re McLean, 794 F. 3d 1313 (11th Cir. 2015) quoting In re Hardy, 97 F. 3d 1384, 1390 (11th Cir. 1996). Bankruptcy courts do not have inherent power to impose criminal contempt sanctions, that is, punitive sanct

Filed 04/06/18 Page 2 of 21 TABLE OF CONTENTS TABLE OF AUTHORITIES ii PRELIMINARY STATEMENT 1 I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL 3 III. THE ORDER DENYING THE MOTIONS TO UNSEAL 6 ARGUMEN

ve journalist at the Miami Herald with over twenty years of experience. For over three years, the Miami Herald has reported on and investigated Mr. Epstein and others who were involved in the sexual abuse of underage girls. Recent court filings, both in federal and state court, have raised new allegatio

I. INTERVENORS' COVERAGE OF ALLEGATIONS AGAINST JEFFREY EPSTEIN AND GHISLAINE MAXWELL 2 II. THE OVERB

tions between those law enforcement agencies and Mr. Epstein's legal defense team, and the ultimate decision

nesses, endanger national security, reveal trade secrets, or implicate duty to protect attorney-client material or confidential client information); Hardy, 2017 WL 6805707, at *6-7 (unsealing transcript of settlement between workers' union and, inter alia, the Trump Organization and holding that, unde

HE NEWS Federal Prosecutors Release Details Of Ghislaine Maxwell's Arrest. ABC World News TonightVi (7/13, story 4, 1:30, Muir, 7.15M) reported "on Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxwell. Authorities now revealing details over her arrest in New Hampshire. The FBI breaking through the door, a

and it was not clear if they are living in the US." Fox News (7/13, Casiano, 27.59M) reports, "Maxwell, 58, faces six charges for conspiring with Epstein in a multi-state sex trafficking ring involving three unnamed minors between 1991 and 1997. A hearing is scheduled Tuesday where a judge will decide

i (7/13, story 4, 1:30, Muir, 7.15M) reported "on Jeffrey Epstein's alleged co-conspirator, Ghislaine Maxw

rces in identifying the estimated sale price." FBI Continues Probe Of Independence, Missouri Government. The Kansas City (MO) Star (7/13, Hancock, Hardy, Vockrodt, 549K) reports, "The FBI has once again requested records from Independence City Hall, the latest in a series of inquiries by federal aut

rt of Allegation of Conflict of Interest Dear Mr. I write to advise you that I have learned that lawyers for a target of one of my investigations, Jeffrey Epstein, have raised ethical concerns regarding my involvement in his potential prosecution in the Southern District of Florida. Specifically, I understand

e raised ethical concerns regarding my involvement in his potential prosecution in the Southern District of Florida. Specifically, I understand that Epstein's attorneys have notified Assistant Attorney General Alice Fisher and/or her staff that I have an actual conflict of interest. As part of pre-indic

awyers for a target of one of my investigations, Jeffrey Epstein, have raised ethical concerns regarding m

tioned name to Lefkowitz. I told him that he was mutual friends with two people whom I respected. I also told Lefkowitz that worked at the Shook, Hardy, and Bacon firm, and that he had worked with Guy Lewis, another of Epstein's attorneys. Later, Lefkowitz called me and said that he had checked on

es 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These ongoing investigations are a powerful countervailing inter

involved in an investigation"; "[t]tle district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv

the Southern District of New York, and the Attorney General for the U.S. Virgin Islands, that investigations surrounding the alleged conduct of Mr. Epstein survive his death. It is unclear who are witnesses or targets of any investigation. These ongoing investigations are a powerful countervailing inter

es 164 and 230 at This Time. Laura A. Menninger Jeffrey S. Pagliuca Ty Gee HADDON, MORGAN AND FOREMAN,

involved in an investigation"; "[title district court was in the best position to weigh these factors") (internal quotations and citation omitted); Hardy, 697 Fed. App'x at 725 (2d Cir. 2017) (noting that courts have found that the following can defeat presumption of access: protection of ongoing inv

From: Martin Weinberg To: "Jeffrey E." <[email protected]> Cc: Martin Weinberg Subj

From: Martin Weinberg To: "Jeffrey E." <[email protected]> Cc: Martin Weinberg

awyer. Alan is currently planning to both attend and argue. To be further discussed - along with the other issues. Letter to FBI Liaison with CC to Hardy,who signs the letters attached for your records. 2d letter in AM although I first want to be verify whether they put your name (with others they wor

rosecution in the insanity trial of serial killer Jeffrey Dahmer rested its case. Dahmer has confessed to k

nto his cigar for a long time, but he never smoked it, he only sniffed it occasionally. “Everybody has their own Laurel HOUSE_OVERSIGHT_015374 and Hardy,” he mused. “A miniature Laurel and Hardy, one on each shoulder. Your little Oliver Hardy bawls you out--he says, ‘Well, this is a fine mess you've g