Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-8109

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

e 1400 FL 33401-5012 Counsel for Defendant Jefj•ey Epstein Brad Edwards, Esq. Fanner, Jaffe, Weissing, Edw

upon review of the book or journal by Epstein's criminal lawyer, Jack Goldberger, Esq., it appeam thc "book" or "journal" doca contain the namea of Epatcin's busiftetts-asseeimes-antl-ether--highlr eetifttleyttitt4-eemtitereittilt settstitive-infermatiett-thttt-wett4d he entirely irrelevant to thio act

Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing par

Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 JANE DOE NO. 2, Plaintiff, VS, JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON I -------------- Related cases: 08-

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NP A i

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

t fact that target letters and subpoenas were issued relating to certain financial offenses. See M·, DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 ( 1989)( disclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing partie

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

fact that target letters and subpoenas were issued relating to certain financial offenses. Sse Lg., DEs 282 and 283 submitted in camera and U.S. v. Zolin, 491 U.S. 554 (1989Xdisclosing materials to the district court does not have the legal effect of terminating a privilege thereby allowing parties t

010 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. I --------------- Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,

OF THE MAGISTRATE'S ORDER DATED JUNE 1, 2010 (DE 555), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

TED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

ee infra. Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials to the district court does not have the legal effect of 4 Case 9:08-cv-80119-KAM Document 559

Case 9:08-cv-80119-KAM Document 560 Entered on FLSD Docket 06/10/2010 Page 1 of 11 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON -------------~/ Related cases: 08-8

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

ROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

Therefore, an in camera hearing should occur to determine what objections and privileges must be raised before further disclosure is made. U.S. v. Zolin, 491 U.S. 554, 575 (1989)(disclosing materials 2 Because of the relief sought in this Rule 4 Appeal, Epstein's civil lawyers have not obtained a cop

that means. 8 So my question specifically on A. is that let's just 9 say you ask about whether Dershowitz had relations with other 10 women in Epstein's house. 11 Do we care? 12 MR. C. COOPER: Yes, your Honor. 13 THE COURT: Why? But if not 14 MR. C. COOPER: Well, your Honor, if Mr. Dershowit

Mr. Dershowitz 15 had relations with others in Mr. Epstein's house that would 16 tend, we believe, to stro

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 will seek privileged materials in light of the crime fraud exception and U.S. v. Zolin at least in the First Circuit. And I think inevitably, your Honor, that will lead to a -- THE COURT: Motion practice. MR. H. COOPER: Yes. And perha

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

documents under seal for in camera review by a neutral and detached magistrate or by court-appointed special masters, see, e.g., United States v. Zolin, 491 U.S. 554, 570-71, 109 S.Ct. 2619, 2629-30, 105 L.Ed.2d 469 (1989); In re Grand July Proceedings, 867 F.2d 539, 540 (9th Cir.1989); In re Impou