Epstein Secrets

torney for another party where a joint defense effort or strategy has been decided upon and undertaken by the parties and their respective counsel. See United States v. Bay State Ambulance and Hosp. 12 EFTA00582868 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG

keep the shared information confidential from outsiders." Ken's Foods, Inc. v. Ken's Steak House, Inc., 213 F.R.D. 89, 93 (D. Mass. 2002). See also United States v. Sawyer, 878 F. Supp. 295, 297 (D. Mass. 1995) (despite similar interests between employer and employee, there was insufficient evidence that comm

gest that any of the other documents claimed to be subject to the attorney-client privilege, actually are. For example, document Bates 19856, from Mike Fisten to Mike Fisten, described as "Investigation into Epstein's planes" (see Comp. Ex. A) is assertedly subject to the attorney-client privilege, but is

in, 495 So. 2d at 262; Alachua Gen. Hosp. v. Zimmer USA, Inc., 403 So. 2d 1087, 1088 (Fla. 1st DCA 1981) (privilege continues after case concludes); United States v. International Business Machs. Corp., 66 F.R.D. 154, 178 (S.D.N.Y.1974) (privilege applies only if the work product was gathered in anticipation o

ny, did Ghislaine Maxwell have to [your three clients]? MR. SCAROLA: Objection, work product. Instruct you not to answer. Id. at 155.6 Q. Who did [Mike Fisten] go to California to interview? MR. SCAROLA: That is work product and I instruct you not to answer. Id. at 170. Q. Did Mr. Fisten interview a per

104 1 2 3 4 on behalf of his clients. MR. CRITTON: So, any question that I ask you with regard to conversations that Mr. Edwards had with the U.S.A.O.'S office, whether it was Mrs. Villafana or anyone else 6 from the time, with regard to the Jane Doe 1 7 and Jane Doe 2 versus U.S.A. case, you w

me you were 16 there did an individual by the name of Ken Jenne 17 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -- 21 A. Yes. 22 Q. -- for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't kn

check the plane as part of their custom's check and asked me to accompany him. advised they had the legal authority to board an aircraft going to the United States. I boarded the plane along with and the other two CBP personnel. We walked the length of the plane and ascertained there was no one on board. We t

the FBI. It is the property of the FBI and is loaned to your agency; it and its contents are not to be distributed outside your agency. Embassy of the United States of America Office of the Legal Attache US Consulate Level 59 MLC Centre 19-29 Martin Place Sydney NSW 2000 File No. 31E-MM-108062\174 03 December 2008 Mr. Vic Sulko

S Consulate Level 59 MLC Centre 19-29 Martin Place Sydney NSW 2000 File No. 31E-MM-108062\174 03 December 2008 Mr. Vic Sulkowski Acting Coordinator Americas, Europe, Middle East & Africa Desk Australian Federal Police Canberra, ACT Australia Re: Jeffrey Epstein Dear Mr. The United States Attorney's Off

enclosed letter to DOB berra, Australia; telephone numbers and The letter references the outcome of a Non-Prosecution Agreement entered into by the U.S. Government and Mr. Jeffrey Epstein. The letter provides with the terms of the Agreement and contact information should she have any questions. On 24/07/06, th

Australia, along with the Australian police for the debriefing. On March 9, 2011, AUSA Civil Attorneys Edwards and Jaffe, Private Investigator Mike Fisten (protect identity) and writer met for the interview at the United States Attorney's Office in Fort Lauderdale, Florida. UNCLASSIFIED 403 EFTA028