4
Shared Docs
4
Same-Page
5 / 7
Mentions
went through these, it 19 seems to me that we have dealt with number 679, 716, in 20 connection with 683, 742, and 774. That deals with the 21 Rodriguez, we call it the unauthenticated hearsay document from 22 a suspect source. They call it the black book. I think the 23 Court heard argument about
that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation case there is more latitude to introducing 6 reputational types of evidence. However, it's important to
UTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794625 71 H3V0GIU1 1 so let meet respond to that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation ca
onor, when I went through these, it seems to me that we have dealt with number 679, 716, in connection with 683, 742, and 774. That deals with the Rodriguez, we call it the unauthenticated hearsay document from a suspect source. They call it the black book. I think the Court heard argument about all of
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there is more latitude to introducing reputational types of evidence. However, it's important to remem
7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3V0GIU1 -1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there
tion with 683, 742, and 774. That deals with the Rodriguez, we call it the unauthenticated hearsay document
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 val H3VOGIU1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there i
spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there is more latitude to introducing reputational types of evidence. However, it's important to rememb
lobe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's butler), who tried to sell ev
f in Australia. S/A Gavin Gumbiner (still at FBI): S/A Gumbiner was the case agent on Operation Stolen Globe, which involved the investigation of Alfredo Rodriguez (Jeffrey Epstein's butler), who tried to sell evidence to Brad Edwards. Group Supervisor Michael Donohoe (retired from FBI): GS Donohoe replaced GS
s advice on some of the issues — legal and non-legal — that arose during the case. Assistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I are friends from my time in Miami. She was a supervisor in Miami although not in my chain of command. I would often speak or email with her j
Entities connected to both Alfredo Rodriguez and Kirkpatrick

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Martha Stewart
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
George Mitchell
PERSON
Donald Trump
PERSON
United States
LOCATION
Lesley Groff
PERSON
Bradley Edwards
PERSONLeon Black
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Bill Clinton
PERSON
Michael Jackson
PERSON
Joe Biden
PERSON
Julie K. Brown
PERSON