Epstein Secrets

nt, any criminal prosecution against Epstein is deferred as long as he abides by the certain terms and conditions contained therein. If at any time the United State's Attorney's Office has reason to believe Epstein is in breach of the Agreement, it need only provide Epstein's counsel with notice of the breach and

asses the circumstances where the act of producing documents in response to a subpoena or production request has a compelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "impl

e 5 of 8 the objection 'so general and sweeping in nature" that they aamount[ed] to a blanket assertion of the privilege: Id. p.11. In the instant Motion for Reconsideration, Epstein has set forth additional facts and detailed reasoning successfully demonstrating how forcing him to answer these requests would realistica

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

ED OBJECTIONS AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Reconsideration and/or for Request Rule 4 Review and Appeal of Portions of the Magistrate's Order (DE 462) pursuant to Rule 60, Fed.R.Civ.P. Rule 4, Rule 4(c) and

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT

bout his assertions in his Motion. Moreover, an FBI Special Agent has already reviewed the book. As indicated in the sworn plea agreement entered by the United States and Alfredo Rodriguez (who possessed the book), the FBI Special Agent found that the book contained "Information material to the Epstein [criminal]

econsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes). Epstein's claim that the b

bout his assertions in his Motion. Moreover, an FBI Special Agent has already reviewed the book. As indicated in the sworn plea agreement entered by the United States and Alfredo Rodriguez (who possessed the book), the FBI Special Agent found that the book contained "Information material to the Epstein [criminal]

econsideration (DE #560). Jane Doe will respond to this amended motion for reconsideration. ARGUMENT Jane Doe has an interest in Jeffrey Epstein's Motion for Reconsideration (DE #560), which should be dismissed as utterly without merit (and seemingly filed simply for obstructionist purposes). Epstein's claim that the b

In the Court's Order of September 26, 2011, granting in part the Petitioners' Motion for finding violations of the CVRA, the Court did not address the United States' argument that there is no remedy available for the Petitioners due in part to their failure to seek a prompt resolution of the case. However, in li

heir failure to seek a prompt resolution of the case. However, in light of the Court's Order, it would seem that this issue is better resolved in a Motion for Reconsideration or on appeal of that ruling rather than in this Supplemental Briefing. Accordingly, the Intervenors' third argument is not addressed herein. 5 EFT