Epstein Secrets

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned

onse to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are pri

dings in support of its determination of which of the documents are, or are not, subject to the work product privilege." Dismas Charities, Inc. v. Dabbs, 795 So. 2d 1038, 1039 (Fla. 4th DCA 2001). The party asserting the privilege must prove that the materials constitute work product. See, e.g., Pru

From: To:" Hess Cc: " " ' Subject: Re: U.S. v. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing Date: Thu, 11 Jul 2019 04:28:37 +0000 Dabbs "Roberta Kaplan" Conlon , Alexandra Elenowitz- Hey

d we will be rooting for you on Monday. Best, Get Outlook for iOS From: Sent: Wednesday, July 10, 2019 10:08:08 PM To: Roberta Kaplan; Conlon; Dabbs; Alexandra Elenowitz-Hess Cc: Subject: RE: U.S. v. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing Or can dial into your conference number

From: ' To: Conlon • , Roberta Kaplan < >, Jenna Dabbs "Alexandra Elenowitz-Hess" Cc: "I C Subject: RE: U.S. v. Epstein, 19 Cr. 490 -- victims' rights re: bail hearing Date: Thu, 11 Jul 2019 00:59:22 +0000 Importance: Normal I'm sorry, this got cut off, let me try o

, Assistant U.S. Attorney Southern District of New York From: Sent: Wednesday, July 10, 2019 20:57 To: =Conlon' < >; 'Roberta Kaplan' ; 'lenna Dabbs' ;'Alexandra Elenowitz-Hess' < > Cc: ic >; Subject: RE: U.S. v. Epstein, 19 Cr. 490 — victims' rights re: bail hearing Hi all, As you may alre

her name, or if I was just given her husband's last name her about it tonight. Also happy to ask her about phone numbers for anyone associated with Epstein. Thanks, Alex Alex Conlon I Kaplan Hecker & Fink LLP Original Message From: Sent: Wednesday, April 3, 2019 3:07 PM ). I'll ask EFTA00030151

here, mailto: > wrote: Sorry for the delay on our end. Robbie is going to be out of town, but Alex Hess (cc'd here) and I, and our colleague Jenna Dabbs (former member of your office), would love to do a proffer with you tomorrow or Friday. We can do it by phone or in person, but would prefer to do i

her name, or if I was just given her husband's last name her about it tonight. Also happy to ask her about phone numbers for anyone associated with Epstein. Thanks, Alex Alex Conlon I Kaplan Hecker & Fink LLP Original Message From: Sent: Wednesday, April 3, 2019 3:07 PM To: Alex Conlon < Cc: Al

GE BREAK --- Hi there, Sorry for the delay on our end. Robbie is going to be out of town, but Alex Hess (cc'd here) and I, and our colleague Jenna Dabbs (former member of your office), would love to do a proffer with you tomorrow or Friday. We can do it by phone or in person, but would prefer to do i