Epstein Secrets

' Rights Act ("CVRA"), 18 U.S.C. § 3771, that affect all crime victims in this Circuit. After over a decade of litigation, the Majority holds that Jeffrey Epsteie's victims were not authorized to bring this petition because the CVRA does not permit stand- alone suits, and, therefore, it should have been dismisse

pstein. In her mandamus petition, Ms. Wild asserts that when federal prosecutors secretly negotiated and executed a non- prosecution agreement with Epstein in 2007, they violated her rights under the CVRA—in particular, her rights to confer with and to be treated fairly by the government's lawyers. We

ida to some extent). While he was in custody on these charges, Epstein was found dead. Statement of Attorney General William P. Barr on the Death of Jeffrey Epstein (Aug. 10, 2018), available at https://www.justice.gov/opa/pristatement-attorney-general-william-p- barr-death-jeffrey-epstein. In June 2020,

t resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identifi

nstruction ... we assume that the legislative purpose is expressed by the ordinary meaning"—not the idiosyncratic meaning—"of the words used." Am. Tobacco Co. v. Patterson, 456 U.S. 63, 68, 102 S.Ct. 1534, 71 L.Ed.2d 748 (1982) (quotation marks and citation omitted). The term "motion" is—and long has bee

KIRKLAND & ELLIS LLP MEMORANDUM Attorney Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz, P.C. Eric F. Leon David S. Flugman DATE: August 7, 2009 RE: Potential Claims against D.B. Zwim

uct Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lefkowitz,

y Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Le

y Work Product Privileged and Confidential TO: Jeffrey E. Epstein CC: Darren K. Indyke FROM: Jay P. Lef

s would rely on the statement. Of course, the statements made by Dubin would have to be false in order to be actionable as well. See Portnoy v. Am. Tobacco Co., No. 96/16323, 1997 WL 638800, at *6 (N.Y. Sup. Ct. Suffolk Co. Sept. 26, 1997). Negligent misrepresentation claims are subject to a six year statu

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this M

FENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this Memorandum of Law as to the Doctrines of Waiver of Attorney-Client and Work Product protections as claimed by Edwards and at issue

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

cy' between lawyer and client does not extend to communications 'made for the purpose of getting advice for the commission of a fraud' or crime. Am. Tobacco Co. v. State, 697 So. 2d 1249, 1253 (Fla. 4th DCA 1997). "If a client communicates with an attorney 17 EFTA00805383 in order to obtain advice or ass