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)

turns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu

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)

turns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu

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

urns] arises 'from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu

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

turns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at •2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu

c. Request Number 13 Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. Response; Defend

urns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu

c. Request Number 13 Request No. 13: A photocopy of your passport, including any supplemental pages reflecting travel to locations outside the 50 United States between 2002 and 2008, including any documents or records regarding plane tickets, hotel receipts, or transportation arrangements. Response; Defend

urns] arises from the need, if tax laws are to function properly, to encourage taxpayers to file complete and accurate returns"). In Pendlebury v. Starbucks Coffee Co., 2005 WL 2105024 at *2 (S.D. Fla. 2005), the court agreed that "[i]ncome tax returns are highly sensitive documents" and that courts should be relu