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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
ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra
tein 12889705 NCA customised Closed - liit 16/06/2017 BIS RESULTS: Negative Media: Mali On I ine MailOnline May 24, 2017 Wednesday 10:53 PM GMT Jeffrey Epstein's 'sex slave' settles her defamation lawsuit against British socia xwell who 'passed her around for sex' and trained her to be 'everything a man wa
recruited her as a sex slave when she was 15 for convicted pedophile billionaire Jeffrey Epstein and passed around to his friends Maxwell, who was Epstein's girlfriend at the time, is also accused of forcing her to have sex with Maxwell and other underage girls The 55-year-old responded to the allegat
ion of Reed Elsevier Inc. All Rights Reserved. Date:6/16/2017 Report processed by: DEUTSCHE BANK AGII Full Name Address County Phone EPSTEIN. JEFFERY E 9 E 71ST ST NEW YORK (212) 750-9895 NEW YORK. NY 10021-4102 (212) 249.1122 NEW YORK COUNTY (212) 772-9416 ADDITIONAL PERSONAL INFORMATION SSN
2546965 (Age 64) Subject Summary Name Variations 1: EDWARDS. JEFFERY 2: EPSTEIN, J 3: EPSTEIN, JEFFERY 4: EPSTEIN, JEFFERY E 5: EPSTEIN, JEFFREY 6: EPSTEIN. JEFFREY E 7: EPSTEIN. JERRERY 8: EPSTIEN, JEFFERY 9: EPTSTEIN. JEFFERY SSNs Summary No. SSN 1: 090-44-XXXX DOBs Reported DO
N. MARK L SSN:117-444OOCX DOB:1955 (Age: 62) EPSTEIN, PAULA A Deceased • AKA EPSTEIN, PAULINE SSN:050-09-XXXX DOB:10/1918 (Age: 98) TUCKER. ELLYN EPSTEIN • AKA EPSTEIN, ELLY • AKA EPSTEIN, ELLYN ELLYN • AKA EPSTEINTUCKER. ELLYN EPSTEIN • AKA EPSTEIN. E • AKA TUCKER. EPSTEIN ELLYN • AKA EPSTEIN-TU
ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel) are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstr
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
ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra
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
ften granted in bad-faith settlement cases, where "mental impressions [of the underlying counsel] are the pivotal issue in the current litigation." Holmgren v. State Farm Mut. Auto. Ins. Co., 976 F.2d 573, 577 (9th Cir. 1992). Other than by analogizing to bad-faith actions, Petitioners have not demonstra
Entities connected to both Jeffrey Epstein and Holmgren
Leon Black
PERSON
Eric Trump
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
Wilbur Ross
PERSON
Jay Lefkowitz
PERSONEmmy Taylor
PERSONRoy Black
PERSON
Michael Jackson
PERSON
Michael Douglas
PERSON
West Palm Beach
LOCATION
Southern District of New York
ORGANIZATION
Supreme Court
ORGANIZATION
United States Department of Justice
ORGANIZATION