Epstein Secrets

e reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCOVERABLE UNDER RULE 501 Jane Doc 1 and Jane Doe 2 are also not entitled to discovery or use of the p

entity of the interviewing agents and the nature of the interview, WILD provided the following information: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with personal massages. WILD was approached at a party by a female she believoi was named CHARLISE. She described

onths, one week and 3 days. EFTA00178032 FD-302a (Rev. 10-6-95) 31E-MM-108062 Continuation of FD-302 of Shawna Lane Rivera .On 05/28/2008 ,Page Epstein offered to pay an extra $100.00 to Rivera if she brought additional girls to him. Epstein asked Rivera to provide a massage to Sarah LNU but the ma

ormation: In 2003 or 2004 WILD was introduced to JEFFREY EPSTEIN for the purpose of providing him with pe

e plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO

arose precisely because, in addition to accelerating the time when a Page 19 party could obtain evidentiary matter from his adversary,PNI the new Federal Rules of Civil Procedure greatly expanded the nature of the material subject to pretrial disclosure/74 *244 Under the Rules, a **2173 party was, for th

ent 545 Entered on FLSD Docket 05/12/2010 Page 1 of 37 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. CASE NO.: 08-CIV-80119-MARR A/JOHNSON Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469,

4, 2010 (DE 462), (DE 480) AND APRIL 1, 2010 (DE 513), WITH INCORPORATED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Consolidated Rule 4 Review and Appeal of Portions of the Magistrate's Orders (DE 462)

o. 19 Beach State Attorney and the USAO may not want to disclose their files for one reason or another. (ii) Third Party Privacy Rights And Judge Jeffrey's Colbath's Order The Magistrate's Order does not consider the privacy rights of other alleged victims. As this Court knows, attached to the NPA is

n fact and opinion attorney work product of both Mr. Epstein's attorneys and government attorneys. Particular

protect the attorneys' mental impressions and to assist the Court in making further determinations as to what information , should be protected by Federal Rules 408, 410, and 502. See supra. Again, as set forth in the Reply attached hereto as Exhibit "B", the USAO and the EFTA00317224 Case 9:08-cv-80119-K

TIGATION Precedence: ROUTINE To: Miami From: Miami PB2/PBCRA Contact: SA Approved By: Drafted By: Case ID #: 31E-MM-108062 (Pending) Title: JEFFREY EPSTEI N; WSTA - CHILD PROSTITUTION Synopsis: To request the opening of sub-files in captioned case. Details: It is requested that the following sub-files

se ID #: 31E-MM-108062 (Pending) Title: JEFFREY EPSTEI N; WSTA - CHILD PROSTITUTION Synopsis: To reque

By: Case ID #: 31E-MM-108062 (Pending) Title: JEFFREY EPSTEI N; WSTA - CHILD PROSTITUTION Synopsis: T

ge need not be tendered to the witness upon service of a subpoena issued on behalf of the United States or an officer or agency thereof (Rule 45(c), Federal Rules of CIA Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of certain indigent parties and criminal defendants who are unable t