Epstein Secrets

onally governed by state regulation). real Rather, its is limited t trafficking that jgntig,0Nop or is accomplished by force, fraud, or coercion". United Stales Evans, 476 ■3d 1176, 1179 it I (I l• Ctr. 2007). Nor, has the Department of Justice deemed it appropriate. e e.g. Unit tates Department of Justic

of several men for conspiracy to hold young women in peonage, and to traffic them for commercial sex acts, involving force and threats; bail issue); United Stares v. 4 A review of the Linked Sutes Department of Justice Civil Rights Division Anti-Trafficking News Bulktins confirms that this same pattern exists

many instances, due to the lack of uniform regulation, these businesses have served to transfer funds which were the proceeds of illegal activity. See United States' Valdes, 2006 U.S. Dist. LEXIS 12432 (S.D.N.Y. 2006) (defendants transmitted proceeds of drug trafficking to Colombia); see also P.L. 103-325, Title

d to protect women agai t conduct, commercial whethv commercial or no t involves transportation and is exploitive or violent. See, e.g., De Vault I United States, 338 2d 179,180 (10th Cir. 1964) (applying the Act to protect girl who was raped). j r The Mann Act is a relatively antiquated morality statute th

d States! Hearn( 381 .3d 80 (2d Cir. 2004) (woman running prostitution business convicted for recruiting and transport of prostitutes under § 2421); United States' Footman, 215 1.3d 145 (I" Cir. 2000) (pimp who ran a prostitution ring convicted of violating § 2421). Likewise, in keeping with its purpose and tit

1/2007 2:24 PM Read. 6/27/2007 4:43 PM Read: 6/21/2007 2:03 PM 118 EFTA00226711 JsI-16-07 I I :00il From-Fowl ur-Illitte Burnett 3057898301 FOWLER WHITE BURNETT P.A. Espirito Santo Plaza Fourteenth Floor 1395 Bnckell Avenue Atom. Florida 33131.3302 (305) 789-9200 Date: To: Fax Number: FAX TRANSMITTAL Mon

n who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr

Beach, FL 33409 (561) 68 561 fax OL Flori No.: 169440 37 EFTA00726035 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian

is often evidence of the most persuasive character."' Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993) (quoting United States ex rel. Bilokumsky v. Tod 263 U.S. 149, 153-154 (1923) (Brandeis, J.). In the circumstances of this case, a reasonable finder of fact would have "ev

ce list. Jack Scarola Searc Denne Scarol Barnhart & Shipley West Palm Beach, FL 33409 By: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbu Goldber er et al. West Palm Beach, FL 33401 Marc S. Nurik, Esq. Law Offices of Ma

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

r riatnuji Respectfully submitted, /s/ Joseph L Ackerman. Jr. Joseph L Ackerman, Jr. Fla. Bar No. 235954 Lilly AIM Sanchez Fla. Bar No. 195677 FOWLER WHITE BURNETT P.A. LI IA.: Co-Counsel for Defendant Jeffrey Epstein bat) W:180743 \MTNPIt007-54411cia Sc. PlokrOos order USDC Dor r lipstelaiLA(9/2/10-1539) -10-

, will take the video deposition of: NAME AJ DiScala DATE AND TIME PLACE Wednesday May 25, 2011 10:30 a.m. Dewey I,eBoeuf 1301 Avenue of the Americas New York, NY 10019 *The deponent has been instructed to bring with him all documents listed in Schedule A attached hereto. upon oral examination

W:1807431Discovery\RE-NTD• DT Al DiscaloacNotice NY 3 By: Joseflh I. Ackerman, Jr. Fla. Bar No. 235954 Lilly A. Sanchez, Fla. Bar No. 195677 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys fo

lls and compromises the presumptive confidentiality of written and often frank discussions between counsel. Epstein intended his communications with United States Attorney's Office to be private and protected by FRE 410. The communications from the U.S. -7- FOWLER WHITE BURNETT, PA. • PHILLIPS Peon - WIRT TOWE

laintiff Respectfidly submitted, /s/ Joseph L Ackerman. Jr. Joseph L Ackerman, Jr. Fla. Bar No. 235954 Lilly A1111 Sanchez Fla. Bar No. 195677 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Co-Counsel f

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an a

r. Epstein's waivers as to jurisdiction, liability and damages only if the identified individuals elect to settle claims pursuant to the Agreement; FOWLER WHITE BURNETT P.A. EFTA00214953 Page 3 — Explaining the capacity of his representation, including an explanation that his role is limited to negotiating settlement

n who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr

/21/2015 Page 40 of Case 09-34791-RBR Doc 1604E8 Filed 04/08/11 Page 39 of 39 SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian

Rule 45(c). Federal Rules of Civil Procedure. 2.-Fees and mileage need not be tendered to the witness upon service of a subpoena issued on behalf of the United Slates or an officer or agency thereof (Rule 45(c), Federal Rules of Civil Procedure; Rule 17(d), Federal Rules of Criminal Procedure) or on behalf of cert

marie- i received your email. i will speak to gerry and get back to you shortly on both items. hope you are well. regards Lilly Ann Sanchez, Esq. FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131-3302 Telephone: (305) 789-9200 Direct Dial: (305) 789-9279 Facsimile

whether pursuant to state, federal, or common law. Notwithstanding this waiver, as to those individuals whose names appear on the list provided by the United States, Epstein's signature on this agreement, his waivers and failures to contest liability and such damages in any suit are not to be construed as an a

r. Epstein's waivers as to jurisdiction, liability and damages only if the identified individuals elect to settle claims pursuant to the Agreement; FOWLER WHITE BURNETT P.A. RFP MIA 000315 EFTA00209003 Page 3 - Explaining the capacity of his representation, including an explanation that his role is limited to negoti