Epstein Secrets

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

S. Dep 't of State v. Washington Post Co., 456 U.S. 595 (1982) 17 United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) 16 United States v. Schwimmer, 892 F.2d 237 (2d Cir. 1989) 14 W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp. 189 (D.D.C. 1996) 11 Williams v. F.B.I., 730 F.2d

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

S. Dep 't of State v. Washington Post Co., 456 U.S. 595 (1982) 17 United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) 16 United States v. Schwimmer, 892 F.2d 237 (2d Cir. 1989) 14 W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp. 189 (D.D.C. 1996) 11 Williams v. F.B.I., 730 F.2d

BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova

1:20-cv-00833-PAE Document 25 Filed 08/05/20 Page 2 of 30 TABLE OF CONTENTS PRELIMINARY STATEMENT BACKGROUND 2 I. Criminal Proceedings Against Jeffrey Epstein 2 II. Criminal Proceedings Against Tova Noel and Michael Thomas 2 III. Criminal Proceedings Against Nicholas Tartaglione 3 IV. The Times's FO

loyees on duty the night Jeffrey Epstein died. Some of the same records could also affect the penalty phase of a pending death penalty case against Epstein's former cell mate. Congress did not intend the Freedom of Information Act, 5 U.S.C. § 552 et seq., to interfere with pending criminal prosecutions.

information, and other personal details of third-party individuals other than Epstein.4 One category of records implicates the privacy interests of Epsteies surviving family members because these records contain highly personal details about his death, including images As a threshold matter, each of the

S. Dep 't of State v. Washington Post Co., 456 U.S. 595 (1982) 17 United States ex rel. Touhy v. Ragen, 340 U.S. 462 (1951) 16 United States v. Schwimmer, 892 F.2d 237 (2d Cir. 1989) 14 W. Journalism Ctr. v. Office of Indep. Counsel, 926 F. Supp. 189 (D.D.C. 1996) 11 Williams v. F.B.I., 730 F.2d

S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA GRAND JURY MATTER FILED UNDER SEAL IN RE GRAND JURY SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND INCORPORATED MEMORANDUM OF LAW Now comes Jeffrey Epstein and respectfully moves this Honorable

Mr. Jeffrey Epstein, including, but not ling to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; ••••••r telephone logs or records

Y SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

span & Stumpf 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131.• Phone: 30S-37f-642i • Fax 305-358006 • vomv.Royalackcom EFTA01713182 Schwimmer, 892 F.2d 237, 243 (2d Cir. 1989). In short, the investigator in turn stands in the shoes oflis client. See Fisher, 425 U.S. at 404. Since producti

eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio

nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo

he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.

also Uni 16 Black. Srebnick. Komspan 201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33B1. Phone: • Fat • vmm.RoyBlackcom EFTA00179005 Schwimmer, 892 F.2d 237, 243 (2d Cir. 1989). In short, the investigator in turn stands in the shoes of his client. See Fisher, 425 U.S. at 404. Since product

dar Online submitted a FOIA requests to the FBI collectively seeking "all documents relating to the FBI's investigation and prosecution of financier Jeffrey Epstein, who plead guilty to one count of felony solicitation of prostitution in August 2006. Dkt. No. 12-2, Ex. B; see Declaration of Michael G. Seidel, da

(b)(7)(A). Many of the records sought by the Radar Online fall at the heart of this exemption, and the FBI has withheld them individually, prior to Esptein's arrest, and categorically, after Esptein's arrest. Other FOIA exemptions also justify the FBI's withholding of records in response to the FOIA re

ecords at the core of the criminal prosecution of Jeffrey Epstein, prior to his passing, and the current p

t matter upon which professional advice is sought, and the confidentiality of the expression for which the protection is claimed." United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. 1989). "[T]he traditional rationale for the [attorney-client] privilege applies with special force in the government co

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned

onse to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are pri

06 S. Ct. 342, 88 L. Ed. 2d 290 (1985); Matter of Bevil!, Bresier & Schulman Asset Management Corp., 805 F.2d 120 (3d Cir. 1986)." United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. N.Y. 1989) (emphasis added). Thus, "parties seeking to invoke the exception must establish that they agreed to engage

Denver, CO 80203 By: Laura A. Henninger, Esq. Jeffrey S. Pagliuca, Esq. USDC SDNY DOCUMENT ELECTRONI

eir respective 14 kr EFTA_R1_00011990 EFTA01734200 Case 1:15-cv-07433-RWS Document 135 Filed 05/02/16 Page 15 of 37 counsel." United States v. Schwimmer, 892 F.2d 237, 243 (2d Cir. 1989). To show the common interest privilege applies, the party claiming its protection must show the communication was