Epstein Secrets

176 Exhibit 1 EFTA00799629 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 26 of 176 U.S. Department of Justice United Slates Attorney Southern District of FlOrida DELIVERY BY BAND James L. Bamberg, Esq. 250 S Australian Ave, Ste104 West Palm Beach, FL 33.401-5007 Dear

uary 24, 2007 Re; Federal _Subpoena have enclosed a new subpoena forTEM MS M I mentioned earlier, Ms. Millis nova target of this investigation and the United States ec s her testimonysolely ea avictim/wituess, Daring our last conyemationregarrling Ms. NiIM you indicated that she was unwilling to speak with us pu

or the Southern District of Florida. I state that there have been no additional promises, agreements pt representations-made to me by any officiala ofthe United States in connection with this matter. Dated: February , 2007 'West Palm Beach, Florida witnessed by: lames la limber Attorney feel= Case No. 08-8073

n. Exhibits designated by a letter are attached to the Government's Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment. 2 EFTA00799607 Case 9:08-cv-80736-KAM Document 403-19 Entered on FLSD Docket 06/02/2017 Page 4 of 176 individuals who had been identified as p

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00071595 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

aived any challenge to this application of Exemption 7(F) in its cross-motion for summary judgment. See Memorandum of Law in Support of Plaintiff's Cross-Motion for Summary Judgment and in Opposition to Defendant's Motion for Summary Judgment ("P. MOL"), at 6 n.2, ECF No. 27. Second, some of the Returned Records contain informa

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00088616 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

aived any challenge to this application of Exemption 7(F) in its cross-motion for summary judgment. See Memorandum of Law in Support of Plaintiff's Cross-Motion for Summary Judgment and in Opposition to Defendant's Motion for Summary Judgment ("P. MOL"), at 6 n.2, ECF No. 27. Second, some of the Returned Records contain informa

, 337 F. Supp. 2d 146 (D.D.C. 2004) 20 Kimberlin v. DOJ, 139 F.3d 944 (D.C. Cir. 1998) 13 Knight First Amendment Institute at Columbia Univ. v. U. S. Dep't of Homeland Security, 407 F. Supp. 3d 334 (S.D.N.Y. 2019) 19 Kubik v. U.S. Fed. Bureau of Prisons, No. 10-6078-TC, 2011 WL 2619538 (D. Or.

ecifically, the events of the night of Epstein's apparent suicide attempt, at issue in Tartaglione. See Letter dated January 13, 2020, Dkt. No. 186, United States v. Tartaglione, No. 16 Cr. 832 (KMK); Letter dated January 21, 2020, Dkt. No. 193, 8 EFTA00099609 Case 1:20-cv-00833-PAE Document 41 Filed 01/15/

aived any challenge to this application of Exemption 7(F) in its cross-motion for summary judgment. See Memorandum of Law in Support of Plaintiff's Cross-Motion for Summary Judgment and in Opposition to Defendant's Motion for Summary Judgment ("P. MOL"), at 6 n.2, ECF No. 27. Second, some of the Returned Records contain informa

ebruary 21, 2019. 1. On February 21, 2019, the Court issued its Opinion and Order granting Petitioners Motion for Partial Summary Judgment, denying the United States's Cross-Motion for Summary Judgment, and ordering the parties to confer and inform the Court by March 8, 2019 regarding how they wish to proceed on

On February 21, 2019, the Court issued its Opinion and Order granting Petitioners Motion for Partial Summary Judgment, denying the United States's Cross-Motion for Summary Judgment, and ordering the parties to confer and inform the Court by March 8, 2019 regarding how they wish to proceed on determining the issue of a remedy.

concede that neither Jane Doe I nor Jane Doe 2 were victims of the crimes to which Epstein entered guilty pleas to on June 30, 2008. D.E. 416 at 40. The United States was not a party to the state court criminal proceeding against Epstein, nor had it initiated those proceedings. Despite all of these facts, petitio

MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff

that "[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion," United States I. Batchelder, 442 U.S. 114, 124 (1979), and the CVRA explicitly states that "[n]othing in th[e] [Act] shall be construed to impair the prosecutoria

ATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. is/Dexter . Lee 31 EFTA00211748 SERVICE

ebruary 21, 2019. 1. On February 21, 2019, the Court issued its Opinion and Order granting Petitioners Motion for Partial Summary Judgment, denying the United States's Cross-Motion for Summary Judgment, and ordering the parties to confer and inform the Court by March 8, 2019 regarding how they wish to proceed on

On February 21, 2019, the Court issued its Opinion and Order granting Petitioners Motion for Partial Summary Judgment, denying the United States's Cross-Motion for Summary Judgment, and ordering the parties to confer and inform the Court by March 8, 2019 regarding how they wish to proceed on determining the issue of a remedy.

concede that neither Jane Doe 1 nor Jane Doe 2 were victims of the crimes to which Epstein entered guilty pleas to on June 30, 2008. D.E. 416 at 40. The United States was not a party to the state court criminal proceeding against Epstein, nor had it initiated those proceedings. Despite all of these facts, petitio

MARY JUDGMENT Respondent United States of America, by and through its undersigned counsel, files its Reply to Petitioners' Response to Government's Cross-Motion for Summary Judgment, and states: I. JANE DOE 2 CLEARLY EXPRESSED HER DESIRE NOT TO BE TREATED AS A VICTIM OF EPSTEIN During the Government's investigation into Jeff

that "[w]hether to prosecute and what charge to file or bring before a grand jury are decisions that generally rest in the prosecutor's discretion " United States v. Batchelder 442 U.S. 114, 124 (1979), and the CVRA explicitly states that "[n]othing in th[e] [Act] shall be construed to impair the prosecutorial

ATE OF SERVICE I HEREBY CERTIFY that on June 6, 2017, the foregoing Response and Opposition to Petitioners' Motion for Partial Summary Judgment and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant U