Epstein Secrets

hat rea a N was told by EPSTEIN that she w to tell anyone wha nac appened during the massages. began avoid in tel phone calls from EPSTEIN and EPSTE s assistant, stated that on each of Ills to EPSTEIN's residence s e a taken a Xanax. However, stated that she Investigation on 10/30/2006 at

but did not want to be interviewed. However, confirme t at she first met JEFFREY EPSTEIN when she was i een or sixteen years old. She was taker o PSTEIN's residence in Palm Beach by one of her good friends. stated that she provided EPSTEIN ssages and that she a provided these massages alone. sta

n 552); Privacy Act of 1974 (PA) (fide 5, United States Code, Section 552a); andlor Litigation. FOIA/PA Requester: Martin Weinberg Subject: Jeffrey Epstein Computer or Case Identification Number: Title of Case: • File 31E-MM-108082-IA Serials Reviewed: All Litigation ri Executive Order Applied

litssage to EPSTEIN. said that she was paid $20 y EPSTEIN and he had given he r an extra $100.00 to give

FOIA/PA Requester: Martin Weinberg Subject: Jeffrey Epstein Computer or Case Identification Number:

an I in so much pain? 'he answer Is uncettain and en still unsure. Guys are suds a waste of time, atWast i thought they were. 'For now Fir Mt a Bogle gishrm Burma stay this fl y, Linn the perfect guy comes Moog and knows gust what to say. •1:'s better to have loved and lost then to have never

provide notice to the victims. It is also needed to demonstrate why the victims at first received inaccurate information about the NPA, as well as Jeffrey Epstein's involvement in that inaccurate notice. See, e.g., DE 48 at 15-16. 43. RFP No. 16 requests documents regarding Bruce Reinhart, a senior prosecutor w

ch re Travel for Prostitution" containing attorney (Villafafta) handwritten notes regarding grand jury presentation, chart entitled "Brought to Epstein's House" with handwritten notes, Message Pad meta- analysis chart, summary of evidence related to one victim/witness, and relevant grand jury inf

serted Victims' Objections Box #3 Folder entitled "Responses to Arguments Work product No Factual Underpinnings; Fiduciary Duty; P-011923 from JE Counsel" containing: Deliberative process Crime-Fraud-Misconduct; Crime-Fraud- Thru ■ 7/13/2007 letter from Lilly Ann 6(e) Misconduct; Not in A

of course, is a defense attorney who represented defendant Epstein. Recording information provided by a defense att

net (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 3 EFTA00179621

e Government has not provided factual material identifying who is the attorney, who is the client, and how the communications were confidential. See Bogle v. McClure, 332 F.3d 1347, 1358 (11th Cir. 2003). 13. Deliberative Process Privilege Privilege Not Properly Invoked - Any deliberative process pri

nt to the victims in this case is clear. In 2007, the FBI determined that both Jane Doe No. I and Jane Doe No. 2 were victims of sexual assaults by Epstein while they were minors beginning when they were approximately fourteen years of age and approximately thirteen years of age respectively. These sexu

of Epstein's sex offenses in Federal Court — Jane Doe No. 1, Jane Doe No. 2, and a victim I will refer to as "S.R." and "M.J.", and other victims of Jeffrey Epstein's abuse as well. If further information is disclosed about this case, that will not discourage them from providing information, but rather will encou

he word "Epstein," " "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh,' r afana, " "Florida SS Foundation," "Starr," "Black," "Goldberger," "Jeffrey," "Australian,"' "Sanchez," "358 El Brillo Way" appears and which are connected to or related to Jeffrey Epstein, Jack Goldberger, or the Jeffrey

t's desire that federal charges be filed against defendant Epstein. In particular, I wrote on behalf of my clients:

riminal prosecution commensurate with the crimes Mr. Epstein has committed, and we further urge you to take th

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown' City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert privile

the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10. 11. 12. 13. 14. 15. l• 16. Weinberg, Martin C-1 of 2 EFTA00209356 17. Doe No. 1,

come of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10. 11. 12. 13. 14. 15. l• 16. Weinberg, Martin C-1 of 2 EFTA00209356 17. Doe No. 1, Jane 18. Do

r rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. The U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein's sexual abuse of the victims and notified them that they were protected "victims" under the CVRA. The Office, however, ultimately reached a plea dea

ell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10.

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle v. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication con

the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. IMPIIPIS 10. Lefkowitz, Jay 11. Perczek, Jackie 12. libuilm.1 13. ra.c....1.„ , ‘,1„ 1. 14.

come of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. IMPIIPIS 10. Lefkowitz, Jay 11. Perczek, Jackie 12. libuilm.1 13. ra.c....1.„ , ‘,1„ 1. 14. Sloman, Jef

7. Ferrer, Wifredo A. 8. Howell, Jay 9. IMPIIPIS 10. Lefkowitz, Jay 11. Perczek, Jackie 12. libuilm.1 13. ra.c....1.„ , ‘,1„ 1. 14. Sloman, Jeffrey 15. 101010MRNI,PIIIIMP 16. Weinberg, Martin C-1 of 2 EFTA00209568 17. Doe No. 1, Jane 18. Doe No. 2, Jane Note: As they have in the court bel

r rights under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771. The U.S. Attorney's Office for the Southern District of Florida investigated Jeffrey Epstein's sexual abuse of the victims and notified them that they were protected "victims" under the CVRA. The Office, however, ultimately reached a plea dea

create the necessary factual support from which this Court could find that he will be injured if the correspondence is provided to the victims. See Bogle. McClure, 332 F.3d 1347, 1358 (1 1 th Cir. 2003) (noting privilege holder not "excused from meeting their burden of proving the communication confi

0 Boston. MA 02116 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00208681

2 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston. MA 02116 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00208681

n. MA 02116 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00208681

rative process is at issue) that have not been proven by any materials in the record. Accordingly, these assertions of privilege are inadequate. See Bogle v. McClure, 332 F.3d 347, 1358 (11th Cir. 2003); Brown v. City of Margate, 842 F.Supp. 515, 520 Should the Court allow the Government to assert pri

stem: Attorneys for the Government Roy Black, Esq. Jackie Perczek, Esq. Jay P. Leflcowitz Martin G. Weinberg, P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 11 EFTA00208766

nberg, P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 11 EFTA00208766

n G. Weinberg, P.C. Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 11 EFTA00208766

Government has not provided factual material identifying who is the attornex, who is the client, and how the communications were confidential. See Bogle I McClure, 332 F.3d 1347, 1358 (11th Cir. 2003) (noting privilege holders not As the Court is aware, the victims have alleged that U.S. Attorney's

From: Richard Kahn < Sent: Wednesday, November 7, 2018 3:23 PM To: Jeffrey Epstein Subject: USVI elections - Mapp vs Bryan in runoff.. > Governor Kenneth Mapp and Albert Bryan will face off in a runoff election on November 20, a

Wednesday, November 7, 2018 3:23 PM To: Jeffrey Epstein Subject: USVI elections - Mapp vs Bryan in runo

Sent: Wednesday, November 7, 2018 3:23 PM To: Jeffrey Epstein Subject: USVI elections - Mapp vs Bryan

. (DEM) . . . . 5,142 8.76 Kenneth Kenny Gittens (DEM) . . . . 4,110 7.00 Oakland Benta (DEM) 4,001 6.82 Genevieve Whitaker 2,545 4.34 Daren "Bogle" Stevens 2,527 4.30 Michael 1 Springer 2,100 3.58 Lilliana Belardo-ONeal (REP). . . . 2,070 3.53 Robert B. Moorhead (REP) 1,962 3.34 Norman