Epstein Secrets

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

(See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O'Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.) (relying on allegations within pleading to decide application of work product privilege)

ions, as well as other privileges and protections, over its internal deliberations in connection with the non- prosecution agreement it reached with Epstein and related discussions about victim notifications. As the Court is aware, the victims have previously-filed a substantial motion for summary judgm

nt Roy Eric Black Jacqueline Perczek Black Srebnick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872 Case 9:08-cv-80736-KAM Document 414-1 Entered on FLSD Docket 08/11/2017 Page 1 of 1 UNITED STATES DISTRICT

uite 1300 Miami, FL 33131 Email: Attorneys for Jeffrey Epstein /s/ Sualey Edeualua II EFTA00799872

ng it relevant to the case; and (3) application of the protection would deny the opposing party access to information vital to its defense. Stern v. O'Quinn, 253 F.R.D. 663, 676 (S.D. Fla. 2008) (citing Granite Partners, L.P. v. Bear, Stearns & Co., Inc., 184 F.R.D. 49, 55 (S.D.N.Y.1999) (citing Heani v

d — indeed, such protection can be waived "impliedly." A very thorough review of the relevant caselaw is found in this Court's decision in Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008). As this Court explained, under the doctrine of implied waiver of work product protection, "a party waives

ng COVID-19 Origins." • Democrats And Republicans Unite Behind Senate Bill Targeting China. CRIMINAL INVESTIGATIONS • Judge Approves Deal To Allow Epstein's Jail Guards Avoid Prison. • Roof Appeals Death Sentence In Charleston Church Mass Shooting. • Police Investigator Accused Officers Of Underplayin

rict Judge Analisa Torres on Tuesday approved a deferred prosecution agreement for "two jail guards who admitted to falsifying records on the night Jeffrey Epstein killed himself on their watch." The deal ends the criminal case against Tova Noel and Michael Thomas and lets them avoid prison. According to Reuter

who admitted to falsifying records on the night Jeffrey Epstein killed himself on their watch." The deal

related charges, the Elizabeth City Police Department said in a statement. Investigators said they're also looking into the possibility of deeming O'Quinn's actions a hate crime." The AP adds, "The women who were struck, both 42, were treated at a hospital and released, police said. They were part of a

m at least six Senate committees, reflects...the urgency of a global semiconductor shortage." CRIMINAL INVESTIGATIONS Judge Approves Deal To Allow Epstein's Jail Guards Avoid Prison. Reuters (5/25, Stempel) reports US District Judge Analisa Torres on Tuesday approved a deferred prosecution agreement f

trict Judge Analisa Torres on Tuesday approved a deferred prosecution agreement for "two jail guards who admitted to falsifying records on the night Jeffrey Epstein killed himself on their watch." The deal ends the criminal case against Tova Noel and Michael Thomas and lets them avoid prison. According to Reuter

s who admitted to falsifying records on the night Jeffrey Epstein killed himself on their watch." The deal

d related charges, the Elizabeth City Police Department said in a statement. Investigators said they're also looking into the possibility of deeming O'Quinn's actions a hate crime." The AP adds, "The women who were struck, both 42, were treated at a hospital and released, police said. They were part of

officer under his direction." Consequently, the discretionary decision not to notify additional victims of the NPA, and risk likely impeachment by Epstein's attorneys if a criminal prosecution ensued, cannot be the basis of a finding that the government violated the CVRA. The main thrust of petitioner

00 Miami , FL 33131 Roy E. Black BLACK SREBNICK KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 1300 Miami FL 33131 Attorneys for Intervenor Jeffrey Epstein 10 EFTA00799973 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 11 of 11 Dexter A. Lee Assistant United States Attor

te 1300 Miami FL 33131 Attorneys for Intervenor Jeffrey Epstein 10 EFTA00799973 Case 9:08-cv-80736-KA

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai

nt argues that its internal deliberations led to a decision not to notify victims because the line prosecutor wanted to avoid the possibility that "Epstein's counsel would impeach the victims and my credibility by asserting that I told victims they could receive money for implicating Epstein." DE 403-10

ick Komspan & Stumpf 201 S Biscayne Boulevard Suite 1300 Miami, FL 33131 305-371-6421 Fax: 358-2006 Email: [email protected] Attorneys for Jeffrey Epstein Is/ &ale. p. 5cloanda 1 I EFTA00600127

2006 Email: [email protected] Attorneys for Jeffrey Epstein Is/ &ale. p. 5cloanda 1 I EFTA00600127

ictims and the Government agree that the relevant legal standard governing the question of waiver of work-production protections comes from Stern v. O'Quinn, 253 F.R.D. 663, 676-77 (S.D. Fla. 2008), which held that "a party waives work-product privilege protection when (1) assertion of the protection re

officer under his direction." Consequently, the discretionary decision not to notify additional victims of the NPA, and risk likely impeachment by Epstein's attorneys if a criminal prosecution ensued, cannot be the basis of a finding that the government violated the CVRA. The main thrust of petitioner

K KORNSPAN & STUMPF 201 S. Biscayne Boulevard, Suite 1300 Miami , FL 33131 Tel: (305) 371-6421; Fax: 305-358-2006 Email: Attorneys for Intervenor Jeffrey Epstein 10 EFTA00601691 Case 9:08-cv-80736-KAM Document 421 Entered on FLSD Docket 08/25/2017 Page 11 of 11 Dexter A. Lee Assistant United States Attor

ax: 305-358-2006 Email: Attorneys for Intervenor Jeffrey Epstein 10 EFTA00601691 Case 9:08-cv-80736-KA

rning its internal deliberations while making representations regarding those deliberations to obtain summary judgment." D.E. 414 at 1. In Stern v. O'Quinn 253 F.R.D. 663 (S.D.Fla. 2008), the district court identified two ways in which the attorney work-product doctrine could be waived. An "implied wai