Epstein Secrets

tion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas 6(e) Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Box #3 P-012130 Thru P-012150 Declaration o i 6(e) Box #3 P-

hibit 6. 17. In the declaration, Ms. makes a number of assertions, including that "there could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; "I believed that if I told the truth about what happened at Epstein's house, the police "; "I had been greatly in

/2013 Page 19 of 23 Bates Range Description Privilege(s) Asserted Box #3 P-011923 Thru P-011966 Folder entitled "Responses to Arguments from JE Counsel" containing: Work product Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (

tified as a potential victim of the lead target, Jeffrey Epstein. 2. After service of the subpoena, Ms.=

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ay litigation or trial as long as they were prepared by or for

A GOVT BOND VISIT OUR IYEASTIE mow.bearsteamscon What's In This Statement Illrrrll.I.1771111 I II You Messages 2 FINANCIAL TRUST CO INC 0/0 JEFFREY EPSTEIN 6100 RED NOOK QUARTER SUITE 83 ST THOMAS VI 00802 Premise or Third Party Repurchase Agreements with Bear,Steams& Co. Inc. outstanding as of date

ssages 2 FINANCIAL TRUST CO INC 0/0 JEFFREY EPSTEIN 6100 RED NOOK QUARTER SUITE 83 ST THOMAS VI 00

I You Messages 2 FINANCIAL TRUST CO INC 0/0 JEFFREY EPSTEIN 6100 RED NOOK QUARTER SUITE 83 ST THOM

order rout hg other than favorable executions or executions of tint orders at no additional charge. STOPr End of Statement OW Mann Stearin Carp. Grolier:OWN Ono Pant r *112014859 FINANCIAL TRUST CO INC armialea Puce September I. 2005 TIRC03.4 SeXeMbPr 30.2005 ACCOUNT %NUM TAXPAYER KAMER Not Ara

nder 18 U.S.C. § 3771(d)(1) that Jane Does 1 through 33 are barred from obtaining relief under the CVRA due to complicity in the crimes committed by Jeffrey Epstein.' Petitioners have withdrawn their third and fourth request for admissions, but still seek four categories of documents in their request for produc

3 through 33 were identified on the list of victims that was prepared by the government pursuant to the terms of the non-prosecution agreement with Epstein. 2 EFTA00618023 Case 9:08-cv-80736-KAM Document 359 Entered on FLSD Docket 02/01/2016 Page 3 of 11 entirely by the government. Despite availing

CVRA due to complicity in the crimes committed by Jeffrey Epstein.' Petitioners have withdrawn their third

pposing party's attorney. The attorney-client privilege and attorney work-product doctrine still apply to matters which have been concluded. FTC v. Grolier. Inc. 462 U.S. 19 (1983) ("[T]he literal language of the Rule [26(b)(3)] protects materials prepared for any litigation or trial as long as they we

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE I). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

. Co. v. Atlanta Gas Light Co., 248 F.R.D. 663,668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule 26(b)(3)] protects materials prepared for ars litigation or trial as long as they were prepared by or f

ed: The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses

ating the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution agreement between the Government and Epstein. (DE 1). The parties and intervenors d

o every privilege asserted. (DE 265). Intervenor Jeffrey Epstein supports the Government's assertion that

Co. v. Atlanta Gas Light Co., 248 F.R.D. 663, 668 (N.D. Ga. 2008). These cases rely on the Supreme Court's dicta in Federal Trade Communication v. Grolier, Inc., that "the literal language of [Rule 26(bX3)] protects materials prepared for ae litigation or trial as long as they were prepared by or for