Epstein Secrets

t of Justice United Stales Attorney Southern District of Florida A. Marie 500 S. Australian Ave 4th Floor Facsimile FACSIMILE COVER SHEET TO: Jack Alan Goldberger DATE: July 8. 2008 FAX NO. PHONE NO. _ # OF PAGES: 3 RE: Jeffrey Epstein FROM: A. VILLAFASIA. Assistant U.S. Attorney PHONE NO. COMMENTS:

ry, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 25b Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: In accordance with the terms of the Non-Prosecution Agreement, on June 30, 2008, the United States Attorney's Office provided you with a list of t

ctim decides 08-80736-CV-MARRA RFP WPB 000512 EFTA00184957 Case 9:08-cv-80736-KAM Document 362-31 Entered on FLSD Docket 02/10/2016 Page 3 of 3 JACK POLDEERGER, ESQ. Jui.v 8,2008 PAGE 2 to pursue damages. If the United States learns that a civil suit has been filed against Mr. Epstein and he has denied t

ation against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

og (DE 216-1), with rearcSsupplemental box No. 3 P-013284 . The entry here reads: "7/10/08 emails, between and and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-client privilege, work product privilege, and del

hone calls (includin telephone logs and telephone billing statements) made by or received by from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telep

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

og (DE 216-1), with re ard to supplemental box No. 3 P-013284 . The entry here reads: "7/10/08 emails betwee' an and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-client privilege, work product privilege, and del

hone calls (includin telephone logs and telephone billing statements) made by or received by from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telep

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

box No. 3 (P-013284). The entry here reads: "7/10/08 emails between J. Sloman and A. Marie Villafafia, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." The log then indicates that the Government is asserting attorney-client privilege, work product privilege, and del

s (including telephone logs and telephone billing statements) made by or received by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telep

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

-013282 to 83). The entry here reads: "7/08/08 email from A. Marie Villafafia to A. Acosta, J. Sloman, K. Atkinson, and FBI re proposed response to Goldberger's letter re victim notification." In responding to defense attorney Goldberger's letter about victim notification, the U.S. Attorney's Office had

s (including telephone logs and telephone billing statements) made by or received by Reinhart from Jeffrey Epstein, the Florida Science Foundation, Jack Goldberger, Alan Dersowitz, Roy Black, Ken Starr, Lillian Sanchez, and any other person involved with the criminal defense of Jeffrey Epstein, including telep

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

were already pending against lender in bankruptcy adversary proceeding. Fed. Rules Civ.Proc.Rule 23(bX3), 28 U.S.C.A. ARGUED: Daniel P. Shapiro, Goldberg, Kohn, Bell, Black, Rosenbloom & Moritz, Ltd, Chicago, Illinois, for Appellant. Gil- bert Scott Bagnell, Bagnell & Eason, L.L.C., Columbia, South

s unquestionably protected from unwarrant- generally only permitted in "extraordinary ed interference by prosecutorial officials; circumstances," Rizzo v. Goods, 423 U.S. whether the investigation actually involved 362, 379, 96 S.Ct 598, 608, 46 L.Ed2d 661 any unwarranted intrusions into their sat

nishment for downloading and uploading child pornography, the greater the customer demand for it and so the more will be produced. United States' Goldberg. 491 F.3d 668. 672 (7th Cr.) (citations omitted), cert. denied,128 S.Ct. 666 (2007); see also Ge. 501 F.3d at 261 ("deterring the production of ch

irect evidence, it may properly be adduced from the conduct of the parti United States, 304 F.24 810, 825 (8th CI and the attending circumstances. Rizzo cert. denied, 871 U.S. 890,C S.Ct 188, 9 LEd.2d 123 (1962); Goode United States, 58 F2d 106, 107 (8th CG. 191222). [24] The conduct of the part

to A. Acosta, J. Sloman, R. Senior, K. Atkinson re "Jeffrey Epstein Agreement" discussing 6/24/08 email from A. Marie Villafafia to R. Black and J. Goldberger concerning the binding nature of the Agreement Attorney-Client Privilege Work Product Deliberative Process No Factual Underpinnings; Fiduciary

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product