Epstein Secrets

nt/Counterclaim Plaintiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for the entry of an Order that (a) directs Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") to make, within ten (10) days of the entry of the Order, a final determination

tiff ALAN M. DERSHOWITZ ("Dershowitz") respectfully moves this Court for the entry of an Order that (a) directs Plaintiffs BRADLEY J. EDWARDS ("Edwards") and PAUL G. CASSELL ("Cassell") (together, "Plaintiffs") to make, within ten (10) days of the entry of the Order, a final determination as to whet

waive privilege at trial to either submit to discovery on that subject or be precluded from relying on the privileged evidence at trial. See, e.g., Intl Tel. & Tel. Corp. v. United TeL Co. of Fla., 60 F.R.D. 177, 186 (M.D. Fla. 1973) ("Fundamental fairness and justice requires that if the defendant inten

ng and Contacts with Peter Skinner, Stan Pottinger, and Brad Edwards EXHIBIT L: Email String Between Peter Skinner and AUSA cc'ing Stan Pottinger, Brad Edwards, and Sigrid McCawley (Feb. 29, 2016—Mar. 5, 2016) (Sealed) EXHIBIT M: Emails between AUSA and Chief of the Criminal Division (Mar. 3, 2016) (Seale

rmation at issue is peculiarly within the possession of the government (e.g., AUSA and AUSA la or others who are adverse to Maxwell (e.g., Boies, Edwards, Skinner, Pottinger). See Cortina, 630 F.2d at 1216 ("The violation here is particularly insidious because it is difficult to uncover misrepresentat

Hampton v. United States, 425 U.S. 484 (1976) 20 In re WinNet R CISC, 2017 WL 1373918 (S.D.N.Y. No. 16MC484(DLC), Apr. 13, 2017) 24 Martindell v. Intl Tel. & Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 18, 21 McNabb v. United States, 318 U.S. 332 (1943) 20 Morales v. Portuondo, 165 F. Supp. 2d 601 (S.D.

e Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim

016, AUSA- I met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regardingJeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for= who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at 1).29 At

.S. 244 (1994) 35,36,41,42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel Coup., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Stipp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 4

ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe

S. 244 (1994) 35,36, 41, 42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 41

ee Ex. 4 at 1).22 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwe

S. 244 (1994) 35,36, 41, 42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 41

1) Doe No. 1. v. United States, 32, 104 33 86 749 F.3d 999 (11th Cir. 2014) 117, 118, 119 Dowling v. United States, 493 U.S. 342 (1990) 52 Edwards v. Mazzuca, No 00 Civ. 2290 (RIS), 2007 WL 2994449 (S.D.N.Y. Oct. 15, 2007) 155 Falter v. United States, 23 F.2d 420 (2d Cir. 1928) 34 Falter,

ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for Virginia Roberts Giuffre, who had al

7, 30, 32 Leocal v. Ashcroft, 543 U.S. 1 (2004) 40 Lighte, 782 F.3d 120 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 98 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) 59, 63, 77, 102 Martindell, 594 F.3d 79 Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019

ee Ex. 4 at 1).27 AUSA-1 agreed to the meeting, and on or about February 29, 2016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim

016, AUSA-1 met with three attorneys—Peter Skinner of Boies Schiller, Brad Edwards, and Stan Pottinger— regarding Jeffrey Epstein. (See Ex. 4 at 1). Edwards and Pottinger were also attorneys for who had alleged that she is a victim of sex crimes perpetrated by Epstein and Maxwell.28 (Ex. 5 at I).29 At t

.S. 244 (1994) 35,36,41,42 Leocal v. Ashcroft, 543 U.S. 1 (2004) 56, 57 Madanes v. Madanes, 186 F.R.D. 279 (S.D.N.Y. 1999) 141 Martindell v. Intl Tel. and Tel. Corp., 594 F.2d 291 (2d Cir. 1979) passim Martinez v. McAleenan, 385 F. Supp. 3d 349 (S.D.N.Y. 2019) 150, 151 Michigan v. Tucker, 4