Epstein Secrets

undersigned Assistant United States Attorney, hereby asks for permission to file a Supplemental ex parte Declaration in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoenas and Cross- Motion to Compel. In support thereof, the United States states the following: 1. The Declara

response consists of rambling generalizations about various areas of the law which have little or nothing to do with the issues actually raised by Epstein, and those sections of the response require no reply. In other portions, however, the government has ignored critical facts, mischaracterized or mis

target surfaces. In re Grand Jury Proceedings in Matter of Freeman, 708 F.2d 1571, 1574-75 (1 1 th Cir. 1983) (citing In re Grand Jury Proceedings (Jeffrey Fine), 641 F.2d 199, 201-03 (5th Cir. 1981)). See also In re Grand Jury Subpoena, 274 F.3d 563, 570 (1st Cir. 2001) ("Colorable claims of attorney-clien

AN & STUMPF, P.A., hereby appears as counsel for Jeffrey Epstein in the above-entitled cause. DATED at Mi

nce of a two-year term of state imprisonment for Mr. Epstein. That offer was not meant as a starting point for

S ATTORNEY VIA FACSIMILE Lilly Ann Sanchez, Esq. Fowler White Burnett 1395 Brickell Ave Fl 14 Miami Florida 33131-3300 Re: Jeffrey Epstein 99 N.E. 4 Simi Ma lt Tdepbone - Facsimile August 3, 2007 Dear Lilly: Thank you for your letter of August 2nd regarding your proposal on how to resolve the

As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing t

r attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." (DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms of the Protective Order, to enable

o between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by t

ully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: s/ Dexter A. Lee DEXTER A. LEE Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4in Street Miami, Florida 33132 (305) 961-9320 Fax: (305) 530-7139 E-mail: [email protected] Attorney for Respondent CERTIFICATE OF SERVICE I

As an initial matter, the motion should be denied because the non-prosecution agreement entered into between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by the United States, either under seal or otherwise. On August 14, 2008, this Court held a telephonic hearing t

r attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard." (DE 26 at 1.) Presumably, petitioners' motion to unseal is an effort to modify the terms of the Protective Order, to enable

o between the United States Attorney's Office and Jeffrey Epstein was never filed in the instant case by t

-Prosecution Agreement. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant U.S. Attorney Fla. Bar No. 0936693 99 N.E. 4in Street Attorney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 2008, I electronically filed the foregoing document wit