Epstein Secrets

ves do not have information bearing on the issues as presently framed. Those individuals are Ghislaine Maxwell, Howard Rubenstein, Ava Cordero, and Alan Dershowitz, who Edwards claims have information regarding victim issues, which allegedly took place before the present litigation. The relevancy of victim iss

axwell, Howard Rubenstein, Ava Cordero, and Alan Dershowitz, who Edwards claims have information regarding v

ine Maxwell, Howard Rubenstein, Ava Cordero, and Alan Dershowitz, who Edwards claims have information

ivision AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 2001). Consequently, Epstein would like to set a motion directed toward the sufficiency of the Privilege Log. 6. Epstein wishes to proceed with discovery of Edwards' alleged damages, but the Motion to Dismiss the Amended Counterclaim is pending, and Epste

litigation Investigative Privilege Acosta, and Alan Santiago regarding results of additional victim-

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Or

ach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss,

rior to that time, although Epstein does not hereby waive the right to an in camera review with respect to any of the other materials referenced in the Privilege Log. Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued non-compliance is palpable. Epstein has been prejudiced