Epstein Secrets

Counsel for Plaintiff Jane Doe 6 EFTA00175540 Case 9:08-cv-8uo04-KAM Document Entered ..i FLSD Docket 09115L . J8 Page 7 of 8 SERVICE LIST Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Lut

natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 C

stion Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Garden

SD Do t 3.8/1b,..,08 Page 4 of 21 Iktb4-1 PLEA IN THE CIRCUIT COURT THE FOLLOVVING IS TO REFLECT Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister _Dellloe a D 06CF009454A Felony Solicitation of Prostitution 1 No 3.FEI rocuring Person Under 18 for

nying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08. (ir) (Entered: 08/06/2008) 08/08/20(8 a r ns KB MOTION Defendant Jeffiwy Epstein's Opposed Motion to Align Response Date by Jeffrey Epstein. (Attachments: # 1 Text of Proposed OrderXTein, Michael) (Entered: 08/08/2008) 08/13/2008

F.3d at 1314. conditions, and sensitive protocols concerning the fact of Epstein's previously disclosed incarceration. See DE 24 in Jane Doe No. 2 I. Epstein, Case No. 9:08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2Q08) (disclosing fact of Epstein's criminal sentence and incarceration); DE 19 in Jane Doe No

1332: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Def

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,liste

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister

a/k/a, JANE DOE NO. 1, Plaintiff, vs. IF'.F .EY EPSTEIN , and Defendants. PLAINTIFF'S REPLY TO OPPOSIT

Case 9:08-cv-80ou4-KAM Document "L . Entered L. FLED Docket 09/05/i...d Page 3 of 14 CASE NO.: 08-80804-CrV-MARRA/JOHNSON cite. See Mitchell'. Brown & Williamson Tobacco Corp., 294 F.3d 1309, 1314 (11th Cir. 2002) (noting as an undisputed point that someone retains their pre-incarceration domicile for purposes of citizens

RK, • App. Div. No. 6081 Respondent, • On Appeal from New York Supreme Court, • New York County, Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM OF LAW IN SUPPORT OF MOTION TO UNSEAL APPELLATE BRIEFS DAVIS WRIGHT TREMAINE LIP Robert D. Balin John M.

iction for Sex Crimes and Designation as a Level Three Sex Offender 3 B. Media Interest in New York and Florida Prosecutors' Lenient Handling of Epstein's Case 5 C. The Post's Efforts to Obtain the Appellate Briefing Filed with the First Department 8 ARGUMENT 9 I. THE POST HAS THE RIGHT TO M

had never spoken to the federal investigators in Florida who had reached the conclusion that Epstein was a serial abuser of underage girls. Id Ex. C. Epstein subsequently commenced this Appeal, seeking to overturn the trial court's ruling that he is a level three sex offender. The appellate briefs submitt

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM

Index No. 30129/10 - against - (Pickholz, J.) JEFFREY E. EPSTEIN, Defendant-Appellant. : x MEMORANDUM O

008), available at https://nypost.com/2008/06/30/jeffrey-epstein-pleads-guilty-to-prostitution-chargest Mother se

n on the disclosure of the appellate briefs. Id. Mr. Epstein's lawyer stated that he would not take a positio

USE EXISTS TO UNSEAL THE APPELLATE BRIEFS 10 CONCLUSION 14 4811-3721-9459v.2 3930033-000039 EFTA00805349 TABLE OF AUTHORITIES Page(s) Cases Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165 (6th Cir. 1983) 13 Daily News, L.P. v. Wiley, 126 A.D.3d 511, 6 N.Y.S.3d 19 (1st Dep't 2015) 10 Danco Labs., Ltd v. Chem.

CROSS-MOTION TO COMPEL The United States of America, by and through the undersigned Assistant United States Attorney, hereby files its response to Jeffrey Epstein's motion to intervene and to quash two grand jury subpoenas issued to William Riley (Subpoena No. OLY-63) and to the Custodian of Records for Riley Ki

ly conflates several concepts involving different privileges that, when dissected, do not apply to the subpoenaed items. The first issue is whether Epsteins Fifth Amendment privilege applies to Riley's production of the computers removed from Epstein's home. The Fifth Amendment privilege "protects a pers

s. In re Grand Jury Proceedings in Matter of Freeman , 708 F.2d 1571, 1574-75 (11th Cir. 1983) (citing In re Grand Jury EFTA00222994 Proceedings (Jeffrey Fine) , 641 F.2d 199, 201-03 (5th Cir. 1981)). See also In re Grand Jury Subpoena , 274 F.3d 563, 570 (1st Cir. 2001) ("Colorable claims of attorney-clie

and OLY-64 UNITED STATES' RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

of the investigation. When Guy Lewis stated that Mr. Epstein was willing to assist in the federal investigatio

not pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., I Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ( "For communications between an attorney and client . . . to be privileged, they must be

undersigned Assistant United States Attorney, hereby asks for permission to file a Supplemental ex parte Declaration in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoenas and Cross- Motion to Compel. In support thereof, the United States states the following: 1. The Declara

response consists of rambling generalizations about various areas of the law which have little or nothing to do with the issues actually raised by Epstein, and those sections of the response require no reply. In other portions, however, the government has ignored critical facts, mischaracterized or mis

target surfaces. In re Grand Jury Proceedings in Matter of Freeman, 708 F.2d 1571, 1574-75 (1 1 th Cir. 1983) (citing In re Grand Jury Proceedings (Jeffrey Fine), 641 F.2d 199, 201-03 (5th Cir. 1981)). See also In re Grand Jury Subpoena, 274 F.3d 563, 570 (1st Cir. 2001) ("Colorable claims of attorney-clien

AN & STUMPF, P.A., hereby appears as counsel for Jeffrey Epstein in the above-entitled cause. DATED at Mi

nce of a two-year term of state imprisonment for Mr. Epstein. That offer was not meant as a starting point for

t pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp., 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ("For communications between an attorney and client . . . to be privileged, they must be c

CROSS-MOTION TO COMPEL The United States of America, by and through the undersigned Assistant United States Attorney, hereby files its response to Jeffrey Epstein's motion to intervene and to quash two grand jury subpoenas issued to William Riley (Subpoena No. OLY-63) and to the Custodian of Records for Riley Ki

ly conflates several concepts involving different privileges that, when dissected, do not apply to the subpoenaed items. The first issue is whether Epsteins Fifth Amendment privilege applies to Riley's production of the computers removed from Epstein's home. The Fifth Amendment privilege "protects a pers

and OLY-64 UNITED STATES' RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

of the investigation. When Guy Lewis stated that Mr. Epstein was willing to assist in the federal investigatio

ot pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ( "For communications between an attorney and client . . . to be privileged, they must be

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

own & Williamson Tobacco CS E. v. Wigand, 1996 WL 350827 (Sup. Ct. OS Co. Feb. 28, 1996), affd, 228 ..2r1187, 643 92 (I st Dep't 1996) 25, 26, 27 Brown & Williamson Tobacco Corp. v. Wigand, 228 lad 187 (1st Dep't 19%) 25, 26 Cazares v. Church of Scientology of Calif, Inc., 444 So.2d 442 (Fla. Dist. Ct. App. 1983) 18 Dam

l identified as Minor Victim-1 to travel from Florida to New York "with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55." Id. ¶ 13. Count Three alleges that Ms. Maxwell conspired to transport "an individual" in inte

would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130

Avenue New York, NY 10022 Phone: 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

h., 464 U.S. 89 (1983) 8 Burrage v. United States, 571 U.S. 204 (2014) 15 Commit. v. Clark, 489 U.S. 726 (1989) 15 Food and Drug Admin. v. Brown & Williamson Tobacco Corp., 529 U.S. 120 (2000) 8 Hudson Valley Black Press v. I.R.S., 409 F.3d 106 (2d Cir. 2005) 8 Kaiser Aluminum & Chem. Corp. v. Bonjorno, 494 U.S.

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOT

, Index No. 30129/10 - against - : (Pickholz, J.) JEFFREY E. EPSTEIN, ; Defendant-Appellant. x NOTICE OF MOTI

written by Rebecca Rosenberg and Danika Fears, which was published by the Post on January 7, 2015, entitled “DA’s office ‘went easy’ on sex offender Epstein.” 4840-5788-8644v. 1 3930033 -000039 HOUSE_OVERSIGHT_016424 --- PAGE BREAK --- os Annexed hereto as Exhibit C is a true and correct copy of an ar

ement about sexual assault — and a decade before the fall of Harvey Weinstein, Bill Cosby and U.S. Olympic gymnastics doctor Larry Nassar — there was Jeffrey Edward Epstein. Epstein, a multimillionaire hedge fund manager whose friends included a constellation of entertainers, politicians, business titans and royalty, fo