Epstein Secrets

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

as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. Smith v. Florida Power & Light Company, 632 So.2d 696, 698 (Fla. 3rd DCA 1994)(even if individual documents are not work- product, "the selection process itself represents defense

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

as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. Smith v. Florida Power & Light Company 632 Sold 696, 698 (Fla. 3 rd DCA 1994Xeven if individual documents are not work- product, "the selection process itself represents defense c

Requet: 19-411 SDNY_GM_00331585 EFTA_OO2O43 I I EFTA02729297 • IN THE DISTRICT COURT OF APPEAL FOURTH DISTRICT OF FLORIDA CASE NO. 4D09-2554 JEFFREY EPSTEIN, Petitioner, vs. STATE OF FLORIDA, PALM BEACH NEWSPAPERS, INC., E.W., and B.B., Respondents. Pending in the Fifteenth Judicial Circuit in and f

of two orders unsealing a non-prosecution agreement and its addendum (collectively the "NPA"), which are records of the trial court below. State v. Epstein, Case Nos. 06 CF9454AMB, 08 CF9381AMB. Petitioner was investigated by the State of Florida for felony solicitation of children for prostitution. (

FOURTH DISTRICT OF FLORIDA CASE NO. 4D09-2554 JEFFREY EPSTEIN, Petitioner, vs. STATE OF FLORIDA, PAL

rd parties" and identifies those third parties as Mr. Epstein's co- conspirators. (Petition at 15). Again, Mr.

Miami, Keith E. Saxe, David C. Shilton and Ellen J. Durkee, Dept. of Justice, Washington. D.C., for arnicus/ U.S. PER CURIAM. AFFIRMED. Wait v. Florida Power & Light Co.. 372 So.2d 420 (Fla.1979). MINER, ALLEN and ICAHN. 33., concur. END OF DOCUMENT 09112/2019 Copr. ° West 1995 No claim to wig. U.S. govt. wor

October 7, 2009 Rich Kahn RE: Jeffrey Epstein STATEMENT OF COSTS EXPENDED $2,883.13 Balance as of September 10, 2009 09-17-09 Wired into account: $75,000.00 $77,883.13 09-15-09 Florida P

October 7, 2009 Rich Kahn RE: Jeffrey Epstein STATEMENT OF COSTS EXPENDED $2,883.13 Balance

October 7, 2009 Rich Kahn RE: Jeffrey Epstein STATEMENT OF COSTS EXPENDED $2,883.13

y Epstein STATEMENT OF COSTS EXPENDED $2,883.13 Balance as of September 10, 2009 09-17-09 Wired into account: $75,000.00 $77,883.13 09-15-09 Florida Power & Light (Olive Avenue) $210.00 09-17-09 Atterbury, Goldberger & Weiss (Story Cowles) $4,230.80 09-18-09 Florida Power & Light (Olive Avenue) $26.77 R