Epstein Secrets

linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove

gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed w

n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

vidual witnesses with knowledge regarding the facts of this case, yet provided addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witnesses such as "all other then-minor girls, whose identities Plaintiff will attempt to determine" and "

ounsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categories of witness

heir counsel) as to just two, Jeffrey Epstein and Alan Dershowitz. Plaintiff then also listed categorie

that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed w

n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims

linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

annot be met with respect to Mr. Rodriguez's deposition testimony. Indeed, the Plaintiff's Motions to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Maxwell was not a party to any of the litigations in which Mr. Rodriguez was deposed; Ms. Maxwell was

clude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise point. Ms. Max

to Exclude Designation of Depositions Excerpts of Alan Dershowitz and Plaintiff argued this precise poi

trial. She has now obtained an agreement to accept service by Mr. Epstein's counsel, mooting any claim that he is unavailable.' With respect to Mr. Rizzo, she concedes he resides within 100 miles of the courthouse, and provides no basis to claim that he cannot be served. Based on these confessions, th

gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed w

n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims

linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims

linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove t

gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed wh

ation against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

ndrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and R

nce Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefko

ment, including efforts by former President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docke

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

gement and/or non-prosecution agreement, including efforts on his behalf by former President Bill Clinton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims allegation that, after Epstein signed the non-prosecution agreement, his performance was delayed w

n, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove the victims

linton, Prince Andrew, and Harvard Law Professor Alan Dershowitz. These materials are needed to prove

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product

r research work at Stanford." Assistant Director Alan E. Kohler Jr. of the FBI's Counterintelligence Di

C-13) (05/07, Staff Writer). EFTA00163402 Virginia Man Who Bankrolled ISIS Erupts in Court, Gets 30-Year Prison Term The Washington Post (05/07, Rizzo) reported that Mohammed Azharuddin Chhipa, a 35-year-old Virginia man, was sentenced to 30 years and four months in prison for sending at least $185

secute him without an indict- ment. See 1 Charles Alan Wright, Fed. Prac- tice & Procedure § 121, at 518

s unquestionably protected from unwarrant- generally only permitted in "extraordinary ed interference by prosecutorial officials; circumstances," Rizzo v. Goods, 423 U.S. whether the investigation actually involved 362, 379, 96 S.Ct 598, 608, 46 L.Ed2d 661 any unwarranted intrusions into their sat