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)

], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence i)410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecuto

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)

], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence if410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecuto

109, 116 (2d Cir.2005) (emphases The express language of Rule 410 also makes clear that "derivative evidence" is never excluded from a proceeding. See United States v. Ruhkowsi, 814 F.2d 594, 599 (11th Cir. 1987). 8 EFTA00205735 Case 9:08-cv-80736-KAM Document 106 Entered on FLSD Docket 10/10/2011 Page 9 of 2

ary of Enclosures" and justified the privilege by characterizing the documents as "attorney-client communication[s]" without explanation.") (citing United States v. Constr. Prods. Research, Inc., 73 F.3d 464, 473 (2d Cir.1996)).8 Once the Government has cataloged the documents in its privilege log, it then bea

ral principle that all relevant evidence is admissible at trial, see Fed.R.Evid. 402, its limitations are not to be read broadly." United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005). The plain language of the rule is narrowly written to cover only a "statement made in the course of plea discussi

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

e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence ¶410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005)("The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecuto

e Positron Signature Deutsche Bank Sutural°, Inc.. a subsidiary of Deutsche Bank AG. conducts investment banking arid securities activities in the Uni ed States 0S-PWM-0106 Cow Pat Auth & T&C (021121CORP 006420 022212 CONFIDENTIAL — PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0001546 EFFA_000 15020 EFTA00

jfriii, aasoeiet:,gn eorpcnnoit Of. :government or govenimenrithagenty. - • • fir--4.0441duct ite "hairless irt thel'irgili allda.cafd elsewhere i; tthe United States tald foreign: countries and to have officeiwititorontsidc the Virgin islands and to hold, purchase,. mortgage,_ and convey real arid Personal .prop

and Other Property may only be used to satisfy Client's indebtedness or other obligations related to Client's retirement aocoungs). 5. Authority to Barrow In case of the sale of any security or other property by 0/351 of Chenes direction and DBSI's inability to timely deliver the same to the pirchener

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

e], in effect, a privilege of the defendant," quoting 2 J. Weinstein & M. Berger, Weinstein's Evidence 1410[05] at 410-43 (1994)); United States v. Barrow, 400 F.3d 109, 116 (2d Cir. 2005X"The underlying purpose of Rule 410 is to promote plea negotiations by permitting defendants to talk to prosecutor

e has overstated Israeli readiness to drop West Bank annexation plans." The English version of the statement by the United Arab Emirates, Israel and the United States in Abu Dhabi "on Monday said the accord had 'led to the suspension of Israel's plans to extend its sovereignty". In contrast, "the Arabic version, c

p if Biden didn't take a tough stand against violence that came after the unrest." The AP <https://apnews.com/64f37850b73c647eaelc2652838B3ee> (9/2, Barrow) reports Biden "said he wants to help 'heal' a city reeling from another police shooting of a Black man. The wounding of Jacob Blake and subsequent

13, Bekiempis, 4.19M) reports, "Maxwell is a citizen of France, prosecutors pointed out, saying that the country 'does not extradite its citizens to the United States pursuant to French law'. Maxwell also has US and UK passports. The filing added that 'the defendant has not only the motive to flee, but the means t

ot just incrementalism, but whole-scale reform." Progressive Groups Forming PAC To Support Police Defunding Advocates. EFTA00150562 The AP (7/13, Barrow) reports that "a coalition of progressive groups is forming a political action committee to back local candidates who want to redirect money away fr

forth below, the subpoena should be quashed.' I. Applicable Law As the defendant acknowledges, she bears the burden of satisfying the standard in United States v. Nixon, 418 U.S. 683 (1974). (Def. Mot. at 1). Pursuant to that standard, the "party seeking issuance of [a Rule 17(c)] subpoena must clear three

the mark. Any statements in the EVCP's files are unlikely to be inconsistent in light of the context in which they were made. See United States v. Barrow, 400 F.3d 109, 123 (2d Cir. 2005) (citing United States v. Strother, 49 F.3d 869, 875 (2d Cir. 1995) for the proposition that an omission in a prior

speaks openly about it in Israel runs the risk of being sentenced to a lengthy prison term. Research SPIEGEL has conducted in Germany, Israel and the United States, among current and past government ministers, military officials, defense engineers and intelligence agents, no longer leaves any room for doubt: W

n Defense Ministry that the drawings would be completed on the letterhead of a British shipyard and flown on a British plane to the British town of Barrow-in-Furness, where the submarines were assembled. Assuring Israel's security was no longer the only objective of the German- Israeli arms cooperatio