Epstein Secrets

to the basis for a potential indictment, sec December 6, 2007 letter from Mr. to Mr. Lefkowitz at 2, 3; see Alm your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in a

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

basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see gim your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in a

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'

basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lelkowitz at 2, 3; see gla your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in a

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

basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 PM, where you state that the list contains "only those `individuals whom [the United States] was prepared to name in an

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

[dJiligent attempts to carry out an obligation." BLACK'S LAW DICTIONARY 169 (8th ed. 2004). See generall

cv-80736-KAM Document 60 Entered on FLSD Docket 04/07/2011 Page 4 of 10 of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., Inc., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[E]ven if material concerning the grand jury

team including Guy Lewis, Lili Ann Sanchez, Roy Black, and, apparently, Professor Dershowitz who said

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

to the basis for a potential indictment, see December 6, 2007 letter from Mr. to Mr. Lefkowitz at 2, 3; see aiv your email to Mr. Lcfkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains "only those 'individuals whom [the United States] was prepared to name in a

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

Dijiligent attempts to carry out an obligation." BLACK'S LAW DICTIONARY 169 (8i6 ed. 2004). See generall

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)). "[E]ven if material concerning the grand jury invest

[djiligent attempts to carry out an obligation." BLACK'S LAW DICTIONARY 169 (8i6 ed. 2004). See generall

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)). "[E]ven if material concerning the grand jury invest