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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
e use fictitious names for all affected parties and furnish only such background facts as arc necessary to provide ambiance. In the fall of 1998, XYZ Corporation (XYZ) began distributing a neoteric medic- al device. Soon after distribution began, XYZ learned that, on some occasions, the device was not funct
erber Et Al V. The Financial Trust Company Et Al PLAINTIFF: Marvin Gerber; Kalma Koenig DEFENDANT: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILING DATE: 8/20/2018 JURISDICTION: Federal Question JUDGE: J. Paul Oetken NATURE OF SUIT: 370 Fraud
ration; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILIN
: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv75
: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv758
RN DISTRICT OF NEW YORK (Foley Square - NYC) Gerber Et Al V. The Financial Trust Company Et Al PLAINTIFF: Marvin Gerber; Kalma Koenig DEFENDANT: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILING DATE: 8/20/2018 JURISDICTION: Federal Question
erber Et Al V. The Financial Trust Company Et Al PLAINTIFF: Marvin Gerber; Kalma Koenig DEFENDANT: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILING DATE: 8/20/2018 JURISDICTION: Federal Question JUDGE: J. Paul Oetken NATURE OF SUIT: 370 Fraud
ration; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILIN
: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv75
: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv758
RN DISTRICT OF NEW YORK (Foley Square - NYC) Gerber Et Al V. The Financial Trust Company Et Al PLAINTIFF: Marvin Gerber; Kalma Koenig DEFENDANT: XYZ Corporation; The Financial Trust Company; Jeffrey E. Epstein; ABC Inc. DOCKET CASE NUMBER: 1:18cv7580 FILING DATE: 8/20/2018 JURISDICTION: Federal Question
ice arranging a highly unusual and secretive non-prosecution agreement. The victims have already explained at length why the correspondence between Epstein's lawyers and government prosecutors is simply not confidential material to which any kind of privilege or other protection could attach. See Jane
able here because it would, at most, bar admissibility of the correspondence into evidence "against the defendant who made the plea" — i.e., against Jeffrey Epstein. But the victims intend to obtain and use the correspondence to seek relief from the Government. Accordingly, the Rule cannot be used to bar the vic
ughly litigated by the defense attorneys' client (Jeffrey Epstein) more than a year ago, and Epstein's arg
nment cites stands for no such broad proposition. Rather, that case involved a situation where for two years the Government had been demanding that XYZ Corporation should waive its privileges and produce various documents 23 EFTA00205750 Case 9:08-cv-80736-KAM Document 106 Entered on FLSD Docket 10/10/2011 P
son To: [email protected] <[email protected]> Subject: Re: amh Date: Sat, 30 Mar 2013 15:45:36 +0000 What's the question on AMH7 From: Jeffrey Epstein [[email protected]] Sent: Saturday, March 30, 2013 09:02 AM Eastern Standard Time To: Melanie Spinella; Eileen Alexanderson Subject: amh
+0000 What's the question on AMH7 From: Jeffrey Epstein [[email protected]] Sent: Saturday, Ma
5:45:36 +0000 What's the question on AMH7 From: Jeffrey Epstein [[email protected]] Sent: Satu
he contributing partner (that is, if the asset had basis). See Treas. Reg. section 1.197-2(g)(4) for the general rules. Example 3-8 EFTA00692353 XYZ Corporation owns and operates a broadcasting station which has been in business since 1985. In January 1995, the corporation purchases additional licenses from
Entities connected to both Jeffrey Epstein and XYZ Corporation
Leon Black
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSONRoy Black
PERSON
Financial Trust Company
ORGANIZATION
Supreme Court
ORGANIZATION
Cynthia Nixon
PERSONFoley Square - NYC
PERSONXYZ Corp.
ORGANIZATIONKalma Koenig
PERSONFrank Rocco Schirripa
PERSONGerber Et Al V.
ORGANIZATIONABC Inc.
ORGANIZATIONDaniel Brett Rehns
PERSONMarvin Gerber
PERSON