Epstein Secrets

e the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it wa

me in an Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9, 2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing JaLe Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); Les also SEC Dresser Indust', Ms , 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't a

e the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it wa

imile: (561) 820-8777 June 12, 2009 DELIVERY BY HAND Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. Re: Jeffrey Epstein Dear Mr. Goldberger: Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides y

as well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and t like.") (citing Dug Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); see also SEC Dresser Indust. la, 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't Nat'

e the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it wa

csimik: (561) 820-8777 June 12, 2009 DELIVERY BY HAND Jack A. Goldberger, Esq. Atteiburv. Goldberger & Weiss. P A Re: Jeffrey Epstein Dear Mr. Goldberger: Pursuant to the terms ofthe Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides yo

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing In.m Dow Jones & Co., Inc.„, 142 F.3d 496, 500 (D.C. Cir. 1998)); see SEC v Dresser Indust'. Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't v

rs tie the list to the Federal Grand Jury investigation and thus to the non-disclosure provisions of F.R.Crim.P 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals `whom it wa

ame in an Indictment as victims of an enumerated offense by Mr. Epstein.'" (emphasis added). On July 9, 2008, you wrote in a follow-up letter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was

s that either testified or were identified during Grand Jury proceedings are subject to the secrecy provisions of F.R.Crim.P 6(e). Ste, tg,,, In re Dow Jones & Co., Inc., 142 F.3d 496, 500 (D.C. Cir. 1998) ("Consistent with these purposes, we have recognized that grand jury secrecy covers `the identities of wit

ein's defense team, including yourself, Professor Dershowitz, former United States Attorney Guy Lewis, Ms. Lilly Ann Sanchez and Messrs. Roy Black, Jack Goldberger, Gerry Lefcourt and Jay Lefkowitz had the opportunity to review and raise objections to the terms of the Agreement. Again, no one raised objections

letters. You continue to refer to tho plea and sentencing es though it will be in January; Mr. Keleher's office has not confirmed any dale; and Mr. Goldberger recently told Marie Vlllafbfia that "there is no date." I must reiterate that a delayed guilty plea and sentencing — now more than two months beyon

ve disclosures of grand jury material, "Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[Elven if material concerning the grand jury inves

e the list to the Federal Grand Jury investigation and thus to the non- disclosure provisions of Fed. R. Crim. P. 6(e). On July 8, 2008, you wrote to Jack A. Goldberger, Esq., and informed him that on June 30, 2008, "the United States Attorney's Office provided [him] with a list of thirty-one individuals 'whom it wa

ry, Goldberger & Weiss, P.A. One Clearlake Centre, Suite 1400 250 Australian Ave S. West Palm Beach, FL 33401-5015 Re: Jeffrey Epstein Dear Mr. Goldberger: Pursuant to the terms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides y

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing in re Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); sce alsq SEC v Dresser hglustr, inc„ 628 F.2d 1368, 1382 (D.C. Cir. 1980); fund for Constitutional Gov't