Epstein Secrets

and communicative, courts have invoked the “required records” exception to the act of production doctrine. See Federal Saving & Loan Ins. Corp. v. Rodrigues, 717 F. Supp. 1424, 1427 (N.D. Cal 1988) (“required records” exception is a Case 9:08-cv-80994-KAM Document 92 Entered on FLSD Docket 05/28/2010

“a compelling need for the tax returns exists because the information contained therein is not otherwise available.” (Appeal, p. 24). However, in the Eleventh Circuit this heightened burden has been rejected. “[T]he Eleventh Circuit does not require a showing of compelling need before tax information may be obtai

Donuts, Inc. v. Mary’s Donuts, Inc., 2001 WL 34079319 (S.D. Fla. 2001), in which the Court applied the higher standard. These cases do not consider the Eleventh Circuit’s opinion in Maddow, and the federal judges in this District over the past five years since Pendlebury have consistently rejected the “compelling nee

is not the only person to have received this impression that she is at risk if she does not accede to Epstein's demands. The Court is familiar with Alfredo Rodriguez, an employee of Epstein who kept a "black book" of the names of minor girls Epstein' was sexually abusing. See Criminal Complaint, U.S. v. Rodrigu

driguez, an employee of Epstein who kept a "black book" of the names of minor girls Epstein' was sexually abusing. See Criminal Complaint, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (doc. #3). Rodriguez stated that he was afraid that Jeffrey Epstein would make him "disappear" unless he had an "insurance p

P. 42(a); United States v. Baldwin, 770 F.2d 1550, 1553 (11th Cir. 1985). The procedures for such nonsummary criminal contempt are well settled. As the Eleventh Circuit has explained, "A federal court may punish contemptuous conduct that occurs outside its presence only after giving notice of the essential facts co

stein's Palm Beach mansion. Rodriguez testified under oath that Dershowitz was at Epstein's mansion when underage girls were there to give massages. Alfredo Rodriguez Depo. at 278:13-25, 279:9-280:2, Jane Doe No. 21 Epstein (excerpts attached as Exhibit 19).24 Rodriguez also testified that Dershowitz stayed at the house

Id. at 76:11-15. In 2009, one of Epstein's most trusted employees was also deposed: Alfredo Rodriguez, the butler at Epstein's Palm Beach mansion. Rodriguez testified under oath that Dershowitz was at Epstein's mansion when underage girls were there to give massages. Alfredo Rodriguez Depo. at 278:13-25

", to the extent discernable, every case brought under §2422(b) in this district includes use of the intemet. There are only four reported cases in the Eleventh Circuit involving use of the phones only: three of them concern telephone calls to travel agencies advertising overseas underage sex touriand involved expli

m Beach firm. tier for sexual exploitation of minors. According to a. FBI Cherscies at CaneaceCat Submating Once CMAAAt_ t agent's affidavit, Alfredo Rod- riguez offered to later sell the Information for $50,000 — Rodriguez caning it the "Holy Grail" or 'Golden Nug- get" — to a government wit- ness, who is

e affidavit The affidavit does not refer to Epstein by came, abet In early November. an underawer FBI agent "la: sent it to make the bury from Rodriguez. Rodriggez, born in 1%•', had told police that he worked for Epstein as a butler,' chauffeur, chef and housetanl sometimes pick- ing ul and clean

ur Office prevails on that issue, the victims would obviously have no claim under the CVRA. The victims would then pursue their appellate rights in the Eleventh Circuit. If, however, the victims prevail on that issue, then your Office would take "no position" on the remedy sought by the victims for the violation of

Additionally, he stated the bed would almost always have to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through M

e to be made after the massage. On January 4, 2006 I interviewed another former houseman, Mr Alfredo Rodriguez. During a sworn taped statement, Mr. Rodriguez stated he was employed by Jeffrey Epstein for approximately six months, from November 2004 through May of 2005. His responsibilities as house manage

JPL/slm Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit. Den Donner v. City of Prichard. Ala. 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 194397482 EFTA00230792 Roy BLACK HOWARD M. SREBNICK Scan A. KO

r subscriber information. I received a -teIeplibne call from State Attorney's Office, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at

ice, who informed me that the former houseman for Jeffrey Epstein, Alfredo Rodriguez, was present at the State Attorney's Office for an interview. Rodriguez was issued an investigative subpoena for an interview on the on-goings at Epstein's house during his employ. I responded to the State Attorney's Of

mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

ich I requested information from Dollar Rent a Car and Jet Aviation. The information requested from Dollar Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the victims. The other subpoena requested was for Jet Aviation for dates and times when Epstein's plan

Rent a Car was for the rented vehicle by Alfredo Rodriguez while under the employ of Epstein for one of the

DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has

ctrine. See Federal Saving & Loan Ins. Corp. v. Rodrigues, 717 F. Supp. 1424, 1427 (N.D. Cal 1988) (“requir

rwise available.” (Appeal, p. 24). However, in the Eleventh Circuit this heightened burden has been rejected. “[T]he

roduce admissible evidence to support the fact." Rodriguez v. City of Miami, Fla„ 907 F. Supp. 2d 1327, 1330

ng cases and concluding "the relevant case law unanimously agrees that the CVRA extends rights to crime victims before charges have been filed"). As the Eleventh Circuit has explained, "Congress is presumed to know the federal courts' interpretation of a statute that it intends to amend," and "[w]here there is no in

1) 28 Fla. L. Weekly Fed. C 2701 6 Jennings v. Rodriguez. 538 U.S. -. -. 138 S. Ct. 830. 843-44, 200 L.E

ssent misses the point: we are not only deciding Ms. Wild's case today. The majority's opinion will set precedent for how CVRA suits will proceed in the Eleventh Circuit. The mere fact that an Assistant United States Attorney in this case recognized certain individuals as victims says nothing about how prosecutors a