Epstein Secrets

as a Page 2 of 6 EFTA00795670 result,. this Court has received clear and convincing evidence that such funds will be immediately transferred to the United Stales: 12. That the Clerk of Court is hereby directed to immediately submit the proper A documentation to the appropriate bank of the Cayman Islands to

of Florida and elsewhere, the defendant, /SCOTT W. ROTHSTEIN, 1,1eZNIK did knowingly conspi federate, and agree with persons known and unknown to the United States Atto mmit offenses against the United States in violation of Title 18, United States Code1S 1956 and 1957, that is: i. to knowingly conduct and a

ation of Title 18, United States Code, Selo 34 and 1343, in violation of Title 18, United States Code, Section 1957. All in violation of Title 18, United Sta ection I 956(h). (Mail and Wi ud C nspiracy, 18 U.S.C. §1349) 1. The General All d paragraphs 5 through 40 of Count I of the Information are r

submitted, Cy, COFFEY BURLINGTON Counsel for Plaintiffs 2699 South Bayshore Drive, Penthouse Miami, Florida 33133 (305) 858-2900 KENDALL OFFEY Florida Bar N . 259861 [email protected] Annexed hereto as Exhibit A is an affidavit from Plaintiff Rosenfeldt attesting to the truthfulness of the a

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)

following Service List in the manner specified by CM/ECF on this 26th day of February, 2010. By: ---f:-'s:~~----:--:---::- ROBE ITTON, JR., ESQ. Florida Bar N . 224 I 62 rcrit@bclclaw om MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive

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. See generally Eisenstadt v. Baird, supra at 454-455 (the right encompasses privacy in one's sexual matters and is not lim

ing request 10 that would result in the required disclosure of communications from the Government counsel to Epstein, that notice be provided to the United States Attorney so they may intervene to protect their opinion work product, assert their rights to confidentiality under FRE 408 and 410, and assert where

ied on the following Service List in the manner specified by CM/ECF on this 26th day of February, 2010. Respectfully s By: ROBE TTON, JR., ESQ. Florida Bar N 224162 rcrit@bc1cla MICHAEL J. PIKE, ESQ. Florida Bar #617296 IER & COLEMAN (Counsel for Defendant Jeffrey Epstein) Certificate of Service Ja

s of Civil Procedure, requires "[a]ny affidavit supporting a motion must be served with the motion." (Emphasis added). Moreover, Local Rule 7.1 C.3, U.S. District Court, Southern District Local Rules, provides "[t]o the extent a party wants the Court to consider affidavits, declarations, or other mater

ply Brief (Exhibit A to DE #217) and grant any additional relief the Court deems just and proper. By: ----t--1-7"'=---- ROBERT D. C ON, JR., ESQ. Florida Bar N . 224162 MICHAEL J. IKE, ESQ. Florida Bar # 17296 DAVID A. Y AREMA, ESQ. Florida Bar No. 12492 Case 9:08-cv-80119-KAM Document 244 Entered