Epstein Secrets

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

eX3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Page 1 of 69 Abbreviation Inadequate Log No Factual Underpinnings Waiver Fiduciary Duty Crime-Fraud-Misconduct F

"Victim Civil Suits" Not privileged. Produced to counsel for Petitioners N/A Box #1 P-003664 Thru P-003678 File folder entitled "Research it JE Websites" containing attorney research Work product Inadequate Log; No Factual Underpinnings; Fiduciary Duty; Not in Anticipation of Litigation;

re Travel for Prostitution" containing attorney (Villafaria) 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 i

ecutor; Overriding Need; Attorney Conduct at Issue Suppl. Box 3 P-013836 Thru P-013837 Palm Beach Daily News Article, "Attorneys want Jeffrey Epstein Agreement Thrown Out," with attorney's notes written on margin Atty work-product Inadequate Log; No Factual Underpinnings; Fiduciary Duty;

recusal of Southern District of Florida, dated July 29, 2011, with attached memorandum from A. Marie Villafafia to Benjamin Greenberg summarizing Jeffrey E stein Investi ation Attorney-Client Privilege Deliberative Process Work Product No Factual Underpinnings; Fiduciary Duty; Not in Anticipation

)(3)(E) The Court Has Inherent Power to Release Grand Jury Materials Victims Have Properly Petitioned for the Release of Grand Jury The CVRA Gives the Court Authority to Release Grand Jury Materials Abbreviation Inadequate Log No Factual Underpinnings Waiver Fiduciary Duty Crime-Fraud-Misconduct Factual Materia

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

urrently-filed such a petition. 6 EFTA00208678 Case 9:08-cv-80736-KAM Document 225 Entered on FLSD Docket 08/16/2013 Page 8 of 10 The CVRA Gives the Court Authority to Release Grand Jury Materials — The Court is obligated to enforce crime victims' rights. 18 U.S.C. § 3771(b)(1) (the court "shall ensure" that crime