Epstein Secrets

tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i 6(e) Box #3 P-

hibit 6. 17. In the declaration, Ms. makes a number of assertions, including that "there could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; "I believed that if I told the truth about what happened at Epstein's house, the police "; "I had been greatly in

/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (

tified as a potential victim of the lead target, Jeffrey Epstein. 2. After service of the subpoena, Ms.=

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

visory Assistant U.S. Attorney in the West Palm Beach office of the U.S. Attorney's Office, and supervised portions of the criminal investigation of Jeffrey Epstein. 8. assisted AUSA Villafana during the criminal investigation of.leffrey Epstein. 9. In his revious capacity as Deputy Chief of the Criminal Div

iated. 5. was the federal prosecutor in the Southern District of Florida assigned primary responsibility for the federal criminal investigation of Epstein during the time when that criminal investigation was open in the U.S. Attorney's Office and while the non-prosecution agreement was negotiated. 6.

ring the time when the criminal investigation of Jeffrey Epstein was opened in the U.S. Attorney's Office

Obscenity Section at the DOJ. At the request of Mr. Epstein's attorneys, he conducted a review of the U.S. A

S OF AMERICA, Respondent. RESPONDENT'S INITIAL DISCLOSURES Respondent United States of America, by and through its undersigned counsel, makes its Initial Disclosures, pursuant to Fed.R.Civ.P. 26(a)(1)(A), and state: Fed.R.Civ.P. 26(a)(1)(A)fil: 1. R. Alexander Acosta Dean, School of Law Florida International

eval service. - OR - Call 1.866.540.8818. US District Court Civil Docket U.S. District - Fiorida Souther (West Palm Beach) 9:09cv80469 Doe II'. Epstein et al This case was retrieved from the court on Sunday, July 18, 2010 Date Filed: Assigned To: Referred To: Nature of suit: Cause: Lead Docket

(Horowitz, Adam) (Entered: 10/21/2009) 10/21/2009 365 NOTICE OF WITHDRAWAL of Motion by C.M.A. re 331 MOTION for Protective Order as to Defendant, Jeffrey Epstein's. Attendance at Plaintiff's Deposition filed by C.M.A. DOCKET CORRECTION SEE DE 363 FOR IMAGE (tp) (Entered: 10/22/2009) 10/21/2009 367 REPLY to R

r) (Entered: 04/21/2008) AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein on May 7. 2008. filed by Jane Doe No. 4. (Herman. Jeffrey) (Entered: 05/22/2008) Plaintiff's MOTION for Entry of Default by Clerk Against Defendant by Jane Doe No. 4. (Attachments: # 1 Exhibit A and B. # 2

0/21/2009) RESPONSE/REPLY to 60 Amended Document Defendant Epstein's Answer & Affirmative Defenses to Plaintiff's F

enior Judge Kenneth L. Ryskamp. (sh) (Entered: 04/30/2009) 05/15/2009 12 "WRONG EVENT USED, RE-DOCKETED AS ENTRY 13 " NOTICE by Jeffrey Epstein of Initial Disclosures (Brewer, William) Modified on 5/19/2009 (Is). (Entered: 05/15/2009) 05/15/2009 Initial Disclosure(s) by Jeffrey Epstein. [See Image at DE #12] (Is

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 17 Civ 616 (JOK ) Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE Defendants. DEFENDANT INITIAL RULE 26(a)(I)(A) DISCLOSURE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, h

E NO. 17 Civ 616 (JOK ) Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE Defendants. DEFENDANT INITIAL RULE

ORK CASE NO. 17 Civ 616 (JOK ) Plaintiff, VS. JEFFREY EPSTEIN, GHISLAINE Defendants. DEFENDANT INITI

dants. DEFENDANT INITIAL RULE 26(a)(I)(A) DISCLOSURE STATEMENT Defendant by and through her attorneys, Steptoe & Johnson LLP, hereby submits her Initial Disclosures pursuant to Rule 26(a)( I )(A) of the Federal Rules of Civil Procedure based upon information currently known or available. PRELIMINARY STATEMENT

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(a)(1) Finally, Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

responsive to this request that are not otherwise protected opinion work product. No production under this request is necessary. 6. Request No. 25—Initial Disclosures under FRCP 26(2)(1) Finally. Petitioners request that the Government comply with its obligation to serve initial disclosures under Federal Rule of