Epstein Secrets

-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL ED RICCI SPECIAL CONSUMER JUSTICE COUNSEL Dear Judge Hafele: Enclosed, please find Jeffrey Epstein's Response in Opposition to ll's Motion for Inspection and to Compel Discovery, which are set for hearing before Your Honor on December 14, 2009 at 8

E FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XWMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR INSPECTION AND TO COMPEL DISCOVERY AND MOTION FOR PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW Defen

in from disclosing the identity of any person who has knowledge or are in possession of physical evidence (i.e. photographs, EFTA00723281 B,B. v, Eosteiq Case No. 502008CA03 XMB AB Epstein's Objections to Request and Motion for Protective Order Page 10 of 22 videos, written statements, etc.) pert

P. 1.280(c), and states: I. Introduction 1. Mr. Epstein's deposition was set for September 2, 2009, and M

Motion to Compel as to certain requests to which Defendant Epstein was asserting a Fifth Amendment privilege. By th

P.A. BERNARD LESEDEKER. MARK T. LL/TTIER. P.A. JEFFREY C. PEPIN MICHAEL J. PIKE HEATHER. MCNAMARA RUDA

of the "photography team," for example, to sneak off and photograph irrelevant portions of the home and either publish or sell the photos. 53. In Wetzel v. Bernstein, plaintiff brought an action against her former employer alleging discrimination and retaliation. 233 F.R.D. 185. Plaintiff asserted th

e reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p

entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described

onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma

ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe

e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

ause "in absence of Fed.R.Cnm.P. 12.2(c), Fell's statements could be used as evidence against him at trial." 0m6 Fell, 372 F.Supp.2d at 758. Drs. Wetzel and Rabun both produced re- ports based on their examinations of Fell. FN15. In late 2002, Federal Rule of Criminal Procedure 12.2 was amended

on admissibility prior to the government's disclosure of the scope of Weiner's projected testimony. Pursuant to the court's April 7 2005 or- der, Wetzel interviewed Fell and prepared a report explaining his findings. Fell, 2006 U.S. Dist. LEXIS 247071 at *8. A video re- cording of the Wetzel intervi

WORK PRODUCT PRIVILEGE AND/OR THE INVESTIGATOR CLIENT PRIVILEGE To: Robert Critton From: William Riley / Paul Lavery Date: August 8, 2009 Re: Epstein /-/ interview Brian Feeney) File: 8577R On Friday, August 7, 2009, Investigator Paul Lavery interviewed Brian Feeney concerning The interview w

he was in high school and again he graduated in 2002. He has no real knowledge of young high school aged girls going to the home of an older male (Jeffrey Epstein) in Palm Beach and being paid for that. He knows in general from the news reports a few years ago but said he did not know or hear of anyone (by na

l aged girls going to the home of an older male (Jeffrey Epstein) in Palm Beach and being paid for that. H

school. Feeney did however suggest that Lavery locate and interview also close to who was a friend of but possibly was . Accordingly Feeney said Wetzel should have more insight of home life and family and others that knew and associated with aside from those already identified in this investigatio

Anne M. (LA) (FBI)" Subject: RE: Before you meet with again Date: Fri, 25 Oct 2019 15:50:03 +0000 Importance: Normal > Anne I'm so sony another Epstein victim showed up yesterday. Call me when your free today. On Oct 24, 2019 3:15 PM, "Wetzel, Anne M. (LA) (FBI)" l> wrote: Any time. On Oct 24, 2

From: "Jackson, Angela (NY) (FBI)" < To: "Wetzel, Anne M. (LA) (FBI)" Subject: RE: Before you meet with again Date: Fri, 25 Oct 2019 15:50:03 +0000 Importance: Normal > Anne I'm so sony another