Epstein Secrets

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?5 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

may violate others third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundam

ce in question contained what would constitute paradigm opinion work product with the single caveat that the opinions of each counsel, Epstein's and the United States Attorney's were exchanged with each other pursuant to the overall expectation that they were safeguarded from disclosure by the policies of confident

iosk records and copies the pages of a traveler's destinations outside of the United States, or does it simply record exit from and entry back into the United States?3 Moreover, it is unclear whether CBP maintains the Sample Customs Declaration Form for any period of time, which form sets out (i.e., if filled out)

may violate others third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundam

travel[ s] in interstate commerce or travels into the United States or ... travels in foreign commerce." Accordingly,

. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038,

luding alleged victims), which would necessarily thwart such individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limi

individuals' rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. &2e generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in ones sexual matters and is not limited to the marital relationship). The Magistrate's

est No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosec

. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038

name in an Indictment as victims of an offense by Mr. Epstein enumerated in 18 U.S.C. §2255. Request No. 2. All documents referring or relating to the United States' agreement with Defendant to defer federal prosecution subject to certain conditions, including without limitation, the operative agreement between

9 Page 32 of 37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundam

ort the invocation of the Fifth Amendment with nothing more than sweeping generalizations applicable to all questions that were asked in discovery. See United States'. Pierce, 561 F.2d 735 (9th Cir. 1977), cert. denied, 435 U.S. 923 (1978) ("a blanket refusal to answer any question is unacceptable"). Defendant Ep

hing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contraceptive device. Yet Defendant relies entirely on Eisenstadt in contending that third party privacy rights provide a basis for Defendant to object to discovery in this case. The vague argument and unsupported

ven the historical record, risks bloody anarchy. And a transitional phase may require an implicit deal between the United States and Iran. Iran and the United States have a record of dealing with each other behind the scenes; the Bush administration and the ayatollahs did likewise in Iraq even as they fought eac

lear diplomacy with Tehran is to succeed, Washington must be prepared for the kind of brinkmanship it has not engaged in since the Cold War," wrote Eisenstadt, in a paper entitled, "Not By Sanctions Alone." And uber-hawks William Kristol and Jamie Fly of the Foreign Policy Institute, a neoconservative thi

gly expects this to happen. Congress adopted the CVRA with the express goal of making the new law "a formula [*855] for success" and a "model for our States." 111 Congress clearly wants the new law aggressively implemented, thereby avoiding the need for further legislative action or even, possibly, a fede

rights of privacy for victims' confidential records). 88 Roe v. Wade, 410 U.S. 113, 152 (1973). 89 Whalen v. Roe, 429 U.S. 589, 599-600 (1977). 9 Eisenstadt v. Baird, 405 U.S. 438, 453 (1972); see also Carey v. Population Servs. Int'l, 431 U.S. 678, 684-85 (1977). DAVID SCHOEN HOUSE_OVERSIGHT_017738 --