Epstein Secrets

7 Attn: AUSAs Maurene Comey, Alison Moe & Alex Rossmiller Re: United States v. Maxwell Dear Counsel: I have been retained on behalf of Professor Alan Dershowitz to provide m opinions as a legal ethics expert regarding prosecutors' candor obligations relating to submissions at Ghislaine Maxwell's upcoming se

incorporate her submission, the prosecution might refer to it, and even if not, the District Judge might rely on it in imposing sentence. Professor Dershowitz has informed the U.S. Attorney's Office ("Office") that Ms. recent civil deposition testimony in their pending case before District Judge Preska es

ict Judge might rely on it in imposing sentence. Professor Dershowitz has informed the U.S. Attorney's Office ("Office"

sel: I have been retained on behalf of Professor Alan Dershowitz to provide m opinions as a legal ethi

sentencing court's decision-making, it is surely the prosecutor." Green, Candor in Criminal Advocacy. supra, at 446; cf. United States v. E.V., 500 F.3d 747, 754 n.12 (8th Cr. 2007) (referring to "prosecutors' obligation to apprise the court of facts relevant to sentencingl. Consequently, the Office

ANTE/ITEM LASTER' WILLIAM R. SAW0 PETER S. THOMAS LAWRENCE SPASOJEVICH SENIOR COUNSEL LOVES R. AIDALA JOSEPH P. BARATTA We are attorneys for Alan Dershowitz ("Professor Dershowitz") in the civil matter of v. Alan Dershowitz endin before Hon. Loretta Preska in the Southern District of New York. lack of

R. SAW0 PETER S. THOMAS LAWRENCE SPASOJEVICH SENIOR COUNSEL LOVES R. AIDALA JOSEPH P. BARATTA We are attorneys for Alan Dershowitz ("Professor Dershowitz") in the civil matter of v. Alan Dershowitz endin before Hon. Loretta Preska in the Southern District of New York. lack of credibility, and actual

. BARATTA We are attorneys for Alan Dershowitz ("Professor Dershowitz") in the civil matter of v. Alan Dershowitz endi

. AIDALA JOSEPH P. BARATTA We are attorneys for Alan Dershowitz ("Professor Dershowitz") in the civil

sentencing court's decision-making, it is surely the prosecutor." Green, Candor in Criminal Advocacy, supra, at 446; cf. United States v. E.V., 500 F.3d 747, 754 n.12 (81° Cir. 2007) (referring to 'prosecutors' obligation to apprise the court of facts relevant to sentencing"). Consequently, the Offic

redacted submissions. It did not request that the district court transmit any unredacted or sealed court submissions. Appeal No. 16-3945. Appellant Dershowitz moved to unseal various documents in August 2016; the district court denied the motion in November 2016. Appellant Cernovich moved to unseal the su

able one. As Lugosch holds, it can be overcome by "specific, on-the- record findings that higher values necessitate a narrowly tailored sealing." 435 F.3d at 126. The Order to Show Cause is improperly dismissive both of the rebuttal of the presumption Ms. Maxwell is entitled to make and the procedure

n Related Cases Nos. 09-80591 and 09-80656 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P

ks. Page 4 haps://web2.westlaw.com/print/printstream.aspx?sv-Split&prft=HTMLE&ifm=NotSet&mt... 6/8/2009 EFTA00182793 Page 2 of 11 Westlaw. 162 F.3d 832 162 F.3d 832 (Cite as: 162 F.3d 832) C United States Court of Appeals, Fifth Circuit. UNITED STATES of America, Plaintiff-Appellee, v. Ra

aw Office of Mark E. Pena, Michael A. Gold, Todd Alan Foster, Cohen, Jayson & Foster, Tampa, FL, G. Ma

why the district court erred in denying the motion. uii Conseq tly, we consider the issue waived. See Wilburn Mid-South Health Dev., Inc., 343 F.3d 1274, 1 1 (10th Cir.2003) ("We ... will not ( consider issues that are raised n appeal but not adequately addressed"); Adler Wal-Mart Stores, In