Epstein Secrets

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

t in camera request - especially when there is a question as to whether those documents were obtained by uulawful means); St. Andrews Park, Inc. v. U.S. Dept. of Army Corps of Engineers, 299 F.Supp.2d 1264 (S.D. Fla. 2003)(court determined that an in camera proceeding was appropriate when it involved a sma

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

h Cir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex M, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

ex M, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed. R. Civ. P. 5.2 19 N.Y. Rules of Professional Conduct, Rule 3.3(d) 24 N.Y. Rules of P

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That was underage when she was brought to New York "for training by Maxwell and Epstein [in] h

OLES SCHILLER AND TO DISMISS COUNTS FIVE AND SIX Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

ir. 1996) 2 Young v. United States, 481 U.S. 787 (1987) 24 Other Authorities Stephen Rex Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed.

Brown, Manhattan federal prosecutors declined to pursue Jeffrey Epstein and Ghislaine Maxwell case in 2016, New York Daily News (Oct. 13, 2020) 11 U.S. Dept. of Justice, JUSTICE MANUAL, JM § 9-11.151 15 Rules Fed. R. Civ. P. 5.2 19 M. Rules of Professional Conduct, Rule 3.3(d) 24 MI. Rules of Profe

al abuse and trafficking by Jeffrey Epstein and Maxwell. Ex. J, pp 1-3. • At the meeting, attorneys told AUSA the following: o That Maxwell was Epstein's "head recruiter" of underage victims. Id. at 2. o That was underage when she was brought to New York "for training by Maxwell and Epstein [in] h

search, no records were found. See Cunningham v. U.S. Dept. of Justice, 961 F.Supp. 2d 226, 236 (D.C. 2013) (

iuffre committed perjury by stating in her previously filed affidavit that it is her recollection that she witnessed former President Bill Clinton on Jeffrey Epstein’s island in the United States Virgin Islands (“USVI’)'. Setting aside Defendant Dershowitz’s baseless claims of perjury, Ms. Giuffre agrees that her c

grees to make his client, Jeffrey Epstein, and others with relevant testimony and with whom he has testified he shares a “common interest” — at least Epstein and Maxwell — available to any law enforcement agency reviewing any alleged criminal activities; or in the alternative, to attest to this Court that

) based on this Court's finding that the government failed to confer with Petitioners prior to entering into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previously found that Petitioners are crime victims under the CVRA; a crime victim's rights under the CVRA attach be

osecutor's conferral obligations; and the government violated the CVRA by failing to advise the victims that it intended to enter into the NPA with Epstein. The government will not EFTA00010542 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 462 Entered on FLSD Docket 06/24/2019 Page 2 of 32 what

ring into a non-prosecution agreement (NPA) with Jeffrey Epstein? Petitioners seek 1 This Court previousl

based on the filing of a "motion asserting a victim's rights" - not a civil complaint or a civil lawsuit. 18 U.S.C. § 3771(d)(3); see Sieverding v. U.S. Dept. of Justice, 693 F. Supp. 2d 93,110 (D.D.C. 2010) (recognizing that it is "only through a motion" that the CVRA "permits" individuals to assert stat

ly in (2) she is a Enational, and (3) according to her lawyer, she recently made a statement to the Met Police reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of the information she may have in connection with our investigation), so we would be open to the possibility of

ice reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of the inform

Met Police reporting some sort of past abuse by Jeffrey Epstein (and not necessarily the full scope of th

ember 29, 2020 6:40 PM To: Cc: c:M > Subject: Re: SDNY investigation My apologies. I haven't been able to get back on the line. John T. McNeil U.S. Dept. of Justice Attaché - London UK Mobile: Sent from a mobile device CRM) From: Sent: Tuesday, September 29, 2020 6:09:57 PM To: McNeil, John T (Lo

on bring this action under the Freedom of Information Act ("FOIA"), seeking records related to the FBI's investigation and prosecution of financier Jeffrey Epstein for child sex trafficking crimes. ( Am. Cmplt. (Dkt. No. 12)) Plaintiff Radar Online is an online investigative news outlet and Plaintiff Robertson

FBI's investigation and prosecution of financier Jeffrey Epstein for child sex trafficking crimes. ( Am.

il 20, 2017, Plaintiff Robertson submitted a FOIA request to the FBI seeking "all documents relating to the FBI's investigation and prosecution" of Epstein. (First Seidel Decl., Ex. A. (FOIA Request) (Dkt. No. 50-1) at 4) On July 2, 2019, Epstein was indicted by a federal grand jury in this District on

agency has the burden of showing that [1] its search was adequate[,] and [2] any withheld documents fall within an exemption to the FOIA." Carney v. U.S. Dept. of Justice 19 F.3d 807, 812 (2d Cir. 1994). A government agency may sustain its burden through "c[a]ffidavits or declarations [that] supply(' fact

Harvard. Asst Sec. for Intergovernmental Affairs, U.S. Dept. of Homeland Security. Jeff Kearl — Chm, SkullCan

From: lan Osbone Sent: 11/28/2012 5:55:14 PM To: Jeffrey Epstein [[email protected]] Subject: Fwd: Invite to Dialog 2014 (16 months away) Importance: — High Same shit. Peter doesn't even attend. I will tell h

n Osbone Sent: 11/28/2012 5:55:14 PM To: Jeffrey Epstein [[email protected]] Subject: Fwd: Invite to D