Epstein Secrets

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF HIS SUPPLEMENT TO MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS, ETC

and/or Waiver of Attorney-Client Privilege and Attorney Work Product With Regard to Sealed Documents, Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), respectfully submits the attached Opinion in the case of Jane Doe No. 1 v. United States, 749 F.3d 999 (11th Cir. 2014), attached to this Notice

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

eving that Bill Clinton was on the airplane with Mr. Epstein and these young woman ..." (18:24- 19:7.) • "I

mpany's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product protection was waived by [party] via production" of the documents in question); In re Columb

case, the victims had (for example) no CVRA right to confer with prosecutors about a secret non-prosecution agreement barring federal prosecution of Epstein for crimes committed against the victims. This position contravenes the CVRA's plain language. The CVRA covers agencies involved in the "detection"

REC. S4260, 54269 (statement of Sen. Feinstein) (discussing § 377 l(d)(1) and explaining "[tjhis provision " The Government also attempts to raise Jeffrey Epstcin's "rights to Due Process." Gov't Resp. at 46. The victims are mystified as to why the Government would want to assert the rights of the criminal who

n- prosecution agreement (NPA) it negotiated with Jeffrey Epstein — an agreement that blocked federal pros

government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con

ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane

able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic

ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg

mpany's disclosure of documents to the SEC during criminal investigation waived work product protections); Grace United Methodist Church v. City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question); In re Columbia

matter, the defense attorneys would suffer no harm from release of the materials. Essentially what the defense attorneys are doing is appearing as Jeffrey Epstein's "next friend" to litigate issues on his behalf. But "a 'next friend' must provide an adequate explanation -- such as inaccessibility, mental incompe

hallenge to the legality of the non-prosecution agreement therefore cannot create a sufficient interest for the defense attorneys to intervene. Only Epstein has an interest in the validity of the non-prosecution agreement, and he has deliberately chosen not to intervene in this case.2 II. THE DEFENSE AT

erns only the crime victims, the Government, and Jeffrey Epstein. Simply put, Roy Black et al. have no rec

e government is no longer confidential — and therefore no longer protected by the work-product doctrine. See Grace United Methodist Church City of Cheyenne, 451 F.3d 643, 668 (10th Cir. 2005) ("any work product objection was waived by [party] via production" of the documents in question). Because no con

Excavator Rental Date: Mon, 14 Feb 2011 17:17:40 +0000 Ok Sony for all the typos .Sent from my iPhone On Feb 14, 2011, at 12:05 PM, "Emad Hanna" Jeffrey, wrote: He is willing to drop the $ 300 mobilization and drop the hourly to $ 165 which will bring his invoice from $ 4,860 to $ 3,960 a savings o

rning to do this? Thank you Emad Hanna Project Controller HBRK Associates 301 East 66th St Suite 10F New York, NY 10065 EFTA00642615 From: Jeffrey Epstein [mailto:[email protected]) Sent: Monday, February 14, 2011 11:14 AM To: Emad Hanna Subject: Re: LSJ Excavator Rental negotiate the invoice„ g

New York, NY 10065 EFTA00642615 From: Jeffrey Epstein [mailto:[email protected]) Sent: Monday, Feb

mobilization charge totaling $ 4,860 I contacted A 9 Trucking and he quoted $ 170 per hour so 3 days would be $ 4,080 (no charge for mobilization) Cheyenne quoted $ 165 per hour and he said he did not need a grapple and the he could move and place stones without it this would come out to $ 4,360 (includ

From: Sent: Wednesday, December 4, 2013 11:06 PM To: Jeffrey Epstein Subject: X5? Attachments: photo 1JPG: Untitled attachment 00016.txt; photo 2JPG; Untitled attachment 00019.txt; photo 3JPG; Untitled attachment

ednesday, December 4, 2013 11:06 PM To: Jeffrey Epstein Subject: X5? Attachments: photo 1JPG: Untitle

Sent: Wednesday, December 4, 2013 11:06 PM To: Jeffrey Epstein Subject: X5? Attachments: photo 1JPG:

goes: I test drove X5 today (again) in the crazy snow. I could ha=e killed us multiple times (tried) and it was really stable. I also test dr=ve the Cheyenne as the dealership was right next to the Audi. Thought to ru=e it out, but it drive like a dream! (Best two for drive: BMW and Porsche) N=t the best

klein To: Karyna Shuliak Subject: Re: orders for JE Date: Thu, 10 Dec 2015 17:13:08 +0000 is it for

age: Customer Service Privacy Policy Satisfaction Guarantee Store Locations Copyright 1986-2015 Sierra Trading Post. Inc.. 5025 Campstool Road. Cheyenne. WV. 82007 From: west elm <[email protected]> Date: September 8.2015 at 12:39:34AM EDT To: Subject: west elm Order Confirmation - #052505

From: Richard Kahn To: "jeffrey E." ,r.jeevacation4striail.com> Subject: couple Date: Fri, 11 Sep 2015 20:32:46 +0000 attached is email sent from Leighton (it appears he has no hard

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