Epstein Secrets

serve the right to appeal your decision to withhold any information. We have included in our submission a Certification of Identity from our client Virginia Roberts, such that records can be released to Sigrid McCawley, her attorney. Sincerely, SSM Enclosures Sigrid S. McCawley EFTA00277523 EXHIBIT A EFTA

lly. During, thi following several months, Prior to her traveling abroad getting her passport. provided them t traveled internationally ssisted GIUFFRE in of passport photographs of herself and he remaining paperwork was taken care of by IIIIIIIIIItraveled to Paris, France, the France, London,

ssion a Certification of Identity from our client Virginia Roberts, such that records can be released to Si

he invitation and made no submission. The court then entered an order granting the motions to co. quash. Applying the balancing test set forth in Douglas Oil Co. v. Petrol Stops Nonhwest, 441 U.S. 211, 99 S.Ct. 1667. 60 L.Ed.2d 156 (1979), the court found that the government had failed to establish a suffic

is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brough

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it

Office of Special Counsel for the investigation of U.S. Secretary of Commerce Ronald Brown; the U.S. Attorney's Office for the Eastern District of Virginia; and the U.S. Attorney's Office of the District of Maryland, where he served as the Chief of the Appellate Division. After leaving federal service,

obtain disclosure and use of grand jury materials covered by the secrecy provisions of Rule 6(e), the petitioner must show a "particularized need." Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 223 (1979). The Douglas Oil Court explained that in order to pierce the veil of Rule 6(e) secrecy, [p]arti

ru P-009271 File folder entitled "[Victim name]/Jane Doe #3" containing meta-analysis of all phone, travel,

ed secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the Ja

is a citizen and resident of the Commonwealth of Virginia, and is sui juris. 2. This Complaint is brough

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it will