Epstein Secrets

he State Attorney's Office, applying pressure against prosecuting the case. The team of attorneys included Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. F4 At some time after the possibility of obtaining a search warrant was discussed, Epstein hired the husband of the

Mr. Black and his firm, Jack Goldberger, Gerald Lefcourt, and Professor Alan Dershowitz. F4 At some time a

ited States I Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum , 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett I Acevedo , 169 F.3d 1155, 1168 (

ct Deliberative process 6(e) Attorney-Client Privilege ■ 7/13/2007 letter from to with handwritten attorney (Lourie) notes; ■ 6/2 /2 I from Gerald Lefcourt Matt Menchal , and with handwritten attorney • ■ 6/25/2007 email fro to Matt Menchel and entitled "Thoughts on Lefcourt's letter" Handwrit

ttorney (Lourie) notes; ■ 6/2 /2 I from Gerald Lefcourt Matt Menchal , and with handwritten attorney

documents that "might allow them to protect those very rights." (lcl at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

fkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken

nvestigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to for

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

T 76" STREET NEW YORK, NEW YORK motal GERALD B. LEFCOURT SHERYL E. REICH RENATO C. STABILE FAITH A. FRI

Attorney Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 July 18, 2007 TELEPHONE FACSIMILE Subpoena Duces Tecum dated June 18, 2007, to Custodian of Records, NES, LLC Dear Ms. I write concerning the grand jury subpoena duces tecum dated June 18, 2007, directe