Epstein Secrets

ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane

able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic

ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg

stitutional considerations" that supposedly undergird plea bargain, the simple fact remains that "there is no constitutional right to plea bargain." Weatherford v. Bursey, 429 U.S. 545, 561 (1977). The Court should not exalt to privileged status negotiations that merely serve the administrative convenience

ane Doe No. 2 ("the victims") respectfully file this opposition to the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense

the motion for a stay pending appeal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referred to as "Epstein"). At issue is correspondence between federal prosecutors and Epstein's criminal defense attorneys concerning plea negotiations. The victims have a

peal filed by intervenors- appellants' Roy Black, Jeffrey Epstein and Martin Weinberg (collectively referre

arn about negotiation on the subject of notifications to crime victims. 4 It is well settled that "there is no constitution right to plea bargain." Weatherford I Bursey, 429 U.S. 545, 561 (1977). A copy of the victims' pleading is attached to this response at Attachment B. 6 Epstein has never contested th

OTHER FBI NEWS • Detroit Police Ramp up Security Measures for 2024 NFL Draft Following Kansas City Super Bowl Parade Shooting • New Lawsuit From Jeffrey Epstein Victims Accuses FBI of Enabling His Sex Trafficking INTERNATIONAL NEWS • Russia Using Thousands of Musk's Starlink Systems in War, Ukrainian Genera

on for more than 20 years. The lawsuit, filed Wednesday in the Southern District of New York, alleges that the FBI turned a blind eye to evidence of Epstein's crimes since the 1990s. The article noted that between 1996 and 2006, the FBI received "reports, complaints and tips concerning the illegal sex tr

y Super Bowl Parade Shooting • New Lawsuit From Jeffrey Epstein Victims Accuses FBI of Enabling His Sex T

Capitol Insurrection Participation Houston Public Media (02/15, Zuvanich) reported that Nathan Mackie from Magnolia, his brother Brandon Mackie of Weatherford, Texas, and their friend Daniel Hatcher of Arkansas were arrested and charged with four federal crimes related to their participation in the Jan. 6

the bastions of an ordered liberty." Edna Selan Epstein, The Attorney—Client Privilege and the Work— *84

Product Doctrine 2 (3rd ed. 1997). Nonetheless, not every intrusion on the attorney-client privilege constitutes a constitutional violation. Under Weatherford v. Bursey, 429 U.S. 545, 554, 97 S.Ct. 837, 843, 51 L.Ed.2d 30 (1977), an intrusion may result in a constitutional violation if privileged informa

as a result of the intrusion; and (4) whether the privileged information was used or will be used to the substantial detriment of the defendants. Weatherford, 429 U.S. at 558, 97 S.Ct. at 845; Kelly, 790 F.2d at 137. While neither the Supreme Court nor this Circuit have yet explained how these factors ar

Plaintiffs, UNITED STATES OF AMERICA, Defendant. REPLY IN SUPPORT OF SUPPLEMENTAL BRIEFING BY LIMITED INTERVENORS BLACK, WEINBERG, LEFKOWITZ, AND EPSTEIN The limited intervenors Black, Weinberg, Lefkowtiz, and Epstein re-file this reply, which is identical to the reply that was previously filed durin

cannot obtain as a matter of constitutional law. Mr. Epstein has performed his side of the bargain with the go

sentence that will be imposed."' Plea negotiations implicate significant constitutional and policy considerations. The plaintiffs argue that under Weatherford Bursey, "there is no constitutional right to plea bargain," but that is not what the case held. What the Supreme Court actually said is that there

venue New York, NY 10022 Laura Menninger, Esq. Jeffrey Pagliuca, Esq. Haddon, Morgan and Foreman, P.C.

has obtained a number of tangible items during its investigation through various means, including search warrants executed at properties of Jeffrey Epstein. We have already produced copies of many of those items in discovery, and, as we previously advised in August 2020, if you wish to inspect any of th

vernment has obtained a number of tangible items during its investigation through various means, including search warrants executed at properties of Jeffrey Epstein. We have already produced copies of many of those items in discovery, and, as we previously advised in August 2020, if you wish to inspect an

e United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") as part of its separate, prior investigation and prosecution of Jeffrey Epstein, as set forth in greater detail in that letter, the Government intends to gather certain martials from USAO-SDFL and conduct targeted searches of t