Epstein Secrets

any work-product protection has been waived or applicable 2 LINK & ROCKENBACH, PA CIVIL TRIAL & APPS 1555 Pairn Beach Lake Blot. Suf. 930 -1Vest PS Beach. FL 33401 - - EFTA00808427 exceptions require disclosure to the state court jury in December. The Honorable Donald J. Hafele in the State Court

otional distress damages is attributable to a disc of e-mails sitting in a box for eight 4 LINK & ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lake: Blvd . Sure 930 - West Pahl Beach. FL 33401 - Tel: waw EFTA00808429 years versus their other life events and choices, including incarceration, e

were resolved in July 2010, and each of the Intervenors executed a full release in favor of Epstein. Any attempt to relitigate the settled 'In the Response, the Intervenors' counsel uses the improper label "victims" 51 times to describe the Intervenors and "sexual abuse" or "sexual assault" 10 times. E

asking Epstein to identify information potentially related to the case(s) including, but not limited to, all employees who performed work inside his Palm Beach residence, all other employees who came to the residence (Interrogatory Nos. 1 — 2), those who gave or were asked to give him massages (Interrogator

of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution, and that in fact, "the

entirely reasonable for Epstein to assert that forcing him to testify as to anyone who came or went to his Palm Beach mansion or was employed at his Palm Beach mansion (Interrogatories 1-2), the identity of persons providing transport services (Interrogatory No. 9), and his employee's telephone numbers (Int

of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution, and that in fact, "the

"declarant" as to the names, addresses, phone numbers or any non-handwritten information Palm Beach Police Report Statements collected by the Palm Beach Police Department from witnesses who had been inside the Epstein mansion Names of witnesses listed in the re .ort• also Plaintiff fails

say without applicable exceptions, or based on other evidentiary grounds. Those issues will be argued at the appropriate time. For purposes of this Response, Ms. Maxwell simply notes the fundamental errors in the Notice, failure to comply with the rules, and general principles that make the residual hea

derable public attention. See, e.g., Palm Beach Post.Com, Banker Epstein Pleads in Prostitution Case, Gets 18 Months (June 30, 2008) ("He lives in a Palm Bea,:h waterfront mansion and has kept company with the likes of President Bill Clinton, Prince Andrew and Donald Trump, but investment banker Jeffrey Eps

On July 7, 2008, the Court directed the Government to file a response to the Petition by July 9, 2008, at 5:00 p.m. The Government has prepared its Response, which is attached as Exhibit A, and the Declaration of Assistant United States Attorney A. Marie Villafana, as well as correspondence with several