Epstein Secrets

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

ice squarely in issue, and, thus, communications embodying the subject matter of the advice typically jo9se protec- tion. See, e.g., United States Bilzerian, 926 F.2d 1285, 1292 (2d Cir.1 I). Imply- ing a subject matter waiver in such a case ensures fairness because it disables litig- ants from using th

eople who achieve great power and wealth, JeffIre]y Epstein exploited the Halo effect to surround himself wi

eliable evidence through a witness plainly incompetent to do so. None of the charges in this case relate in any way to the defendant's appraisal of Jeffrey Epstein's character or whether the defendant did or did not view him in the manner suggested by the Halo effect. Simply put, if every word that Dr. Dietz said

notes that "Dr. Dietz is also prepared to address Jeffrey Epstein's sexual behavior should it prove releva

c., 16 Civ. 01056, 2019 WL 6053223 (M.D. Pa. Nov. 15, 2019) 28, 29, 32 United States v. Amaral, 488 F.2d 1148 (9th Cir. 1973) 27 United States v. Bilzerian, 926 F.2d 1285 (2d Cir. 1991) 18 United States v. Carter, 410 F.3d 942 (7th Cir. 2005) 26 United States v. Curry, 977 F.2d 1042 (7th Cir. 1992)

f the media and claims to have looked at the journal to "refresh [her] memory about this time." See, e.g., Michael Baker, "The First Women to Report Jeffrey Epstein," The Daily Podcast, NY Times (Aug. 26, 2019), Tr. at 2 ("When I was looking, trying to refresh my memory about this time, I came across this journa

vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac

York, NY 10007 Haddon, Morgan and Foreman. t.c Jeffrey PaglIuca 150 East 10th Avenue Denver. Colorado

rocess from selectively disclosed and potentially misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Assin of America v. Shamrock Broadca

ions, as well as other privileges and protections, over its internal deliberations in connection with the non- prosecution agreement it reached with Epstein and related discussions about victim notifications. As the Court is aware, the victims have previously-filed a substantial motion for summary judgm

nt Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872 Case 9:08-cv-80736-KAM Document 414-1 Entered on FLSD Docket 08/11/2017 Page 1 of 1 UNITED STATES DISTRICT

uite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872

te Partners, L.P. v. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 55 (S.D.N.Y.1999) (citing Heani v. Rhay, 68 F.R.D. 574, 581 (E.D.Wash.1975); U.S. v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir.1991); In re Kidder Peabody Securities Litigation, 168 F.R.D. 459, 468-69 (S.D.N.Y.1996); Tribune Co. v. Purcigliotti,

2018-10-25 15:10:33 (UTC) Sender: Self c:'ecitunes il.com Participants: ( ), Self ( [email protected] ) As the new series is called MISTRESS Epstein. I was surprised to see familiar bodies suspended by their balls iMessage [1] 2018-10-25 15:10:49 (UTC) Sender: Self e:'eeitunes mail.com Parti

blowing up by 12 EFTA_R1_01140358 EFTA02295640 iMessage 2018-10-28 18:15:02UTC) 8 Sender: Participants: ( ), Self ( c:[email protected] ) Dear Jeff, my US number will be deactivated end October. This is my Slovak number. Best, Miro iMessage [8] 2018-10-28 18:18:28 (UTC) Sender: Self e:'eeitun

icipants: ( ), Self( [email protected] ) iMessage 2018-10-25 16:09:51 TC I Sender: Participants: ( ), Self( [email protected] ) (Man Bilzerian is the only one flexing on you iMessage [4] 2018-10-26 08:15:56 (UTC) Sender: Self ( e:jeeitunes il.com ) Participants: Eva ( ), Self ( cieeitu

exing to say the least. Milken flunkie Leon Black/Epstein: ESSW was also perplexing. AQR/Singer/Crede/Peiz

ters and complex class action litigation. www.paulweiss.com Who is following me on Twitter: Seems there is a connection between Dan Instagram King Bilzerian, Trump, Rand Paul, and the Jan 6 insurrectionists Oathkeepers. The coincidences are REMARKABLE! Dan Instragram King Bilzerian/Trump/Rand Paul/Oathk

York, NY 10007 Haddon, Morgan and Foreman. r.c Jeffrey Paglluca Denver. Colorado 80203 Re: Response t

im Compensation Fund. She claims to have kept a journal for a period in 1996 in which she described various events, including her interactions with Jeffrey Epstein. Seven (7) photocopied pages of this journal, two of which are the front and back covers, were selectively produced by BSF in discovery during civil

vers, were selectively produced by BSF in discovery during civil litigation to counsel for Ms. Maxwell, apparently as support for her claims against Epstein. The civil litigation was stayed and ultimately dismissed prior to resolution of questions related to the failure to produce the entire journal. Ac

rocess from selectively disclosed and potentially misleading evidence." In re von Bulow, 828 F.2d 94, 102 (2d Cir. 1987); see also United States v. Bilzerian, 926 F.2d 1285, 1292 (2d Cir. 1991); Joy v. North, 692 F.2d 880, 893-94 (2d Cir. 1982); Teachers Ins. & Annuity Assin of America v. Shamrock Broadca

SUPERSEDING INDICTMENT FOR PRE-INDICTMENT DELAY Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN &

is type of selective disclosure by one party in litigation is disfavored. See, e.g., United States v. Nobles, 422 U.S. 225, (1975); United States v. Bilzerian, 926 F.2d 1285 (2d Cir. 1991); In re Grand Jury Proceedings, 219 F.3d 175, 182-84 (2d Cir.2000); Granite Partners, L.P. v. Bear, Stearns & Co., Inc