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

protection. In this case, Epstein's attorneys' disclosure to the United States Attorney's Office was plainly a disclosure to a potential adversary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein's sexual crimes against minor females within the Southern District of Florida

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

er Rule 6(eX3)(AXii) or (iii). 2 EFTA00600055 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's Office was plainly a disclosure to a potential adversary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein' sexual crimes against minor females within the Southern District of Florida an

tervenors Roy Black, Martin Weinberg, and Jay Lefkowitz's opposition to the motion, including motion for protective order [DE 160, 161]; intervenor Jeffrey Epstein's opposition to the motion, including motion for protective order [DE 162]; intervenors' notice of supplemental authority in support of asserted comm

Rule 6(e)(3)(A)(ii) or (iii). 2 EFTA00602808 Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 3 of 11 work-product of Epstein's legal counsel; (2) the correspondence is protected under grand jury secrecy principles codified at Fed. R. Crim. P. 6(e) because its subject matte

District of Florida (USAO/SDFL) and counsel for Jeffrey Epstein to prove the Crime Victims' Rights Act (C

Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's Office was plainly a disclosure to a potential adversary. The United States Attorneys' office, at that juncture, was reviewing evidence relating to Epstein' sexual crimes against minor females within the Southern District of Florida an