Epstein Secrets

ida 3340) Facsimile- FACSIMILE COVER SHEET TO: JIM EISENBERG E_SQ. DATE: February 5, 2007 FAX NO. PHONE NO. # OP PAGES: FROM: ASSISTANT U. S . ATTORNEY PHONE NO. COMMENTS: 3(1/1_- &at- °L4191-fr\k' -61r ougar&cLau ' V IA P i t 'an t_ I t itifft attia 1 1'6 ffidgAgr. Case No. 08-80

T OF FLORIDA NORTHERN (WEST PALM BEACH) DIVISION FGJ NO. 07-103 (WPB) IN RE: GRAND JURY PROCEEDINGS / SEALED ORDER It is hereby ordered that the United States' Sealed Motion for Permission to Disclose Grand Jury Material and the Order granting same be SEALED until further Order of this Court, except that a

new grand jury has been tided and I have enclosed a new subpoena for= MI. As 1 mentioned earlier, Ms is not a target of this investigation and the United States seeks her testimony solely as a victim/winless. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us

F AMERICA, Respondent. UNITED STATES' NOTICE OF FILING PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto.

States respectfully requests that the Application and any Order related to the Application be sealed. Dated: May 30, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ASSISTANT U.S. ATTORNEY Florida Bar No. 500 South Australian Ave, Suite 400 West Palm Beach. Florida 33401 Tel: EFTA00086375 UNITED STATES DI

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

pplied to bar their claims. The government's cross-motion for summary judgment should be granted. DATED: October 10, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY 29 EFTA00800036 Case 9:08-cv-80736-KAM Document 427 Entered on FLSD Docket 10/10/2017 Page 30 of 32 By: s/ Dexte

e, and so on, are for the Attorney General and the President to evaluate. The Judicial Branch is limited to assessing counsel's public deeds." In re United States 298 F.3d 615, 618 (7th Cir. 2005). In short, petitioners are not entitled to "test the bona fides" of the discretionary decision made by prosecutor

the government's cross-motion for summary judgment. Consequently, their motion should be denied. DATED: August 25, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Sui

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

gment based on the undisputed factual record that has since been developed in this case. 111 /// /// 30 EFTA00211747 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Attorneys for the Government CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Respo

its legal impact as opinion and conclusion, not an assertion of fact. . 39. The Government admits that the NPA provided that, upon its execution, "the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall 5 EFTA00799807 Case 9:08-cv-80736-KAM Document 407 Enter

-13. /// /// /// 20 EFTA00799822 Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 21 of 22 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suit

e, and so on, are for the Attorney General and the President to evaluate. The Judicial Branch is limited to assessing counsel's public deeds." In re United States 298 F.3d 615, 618 (7th Cir. 2005). In short, petitioners are not entitled to "test the bona fides" of the discretionary decision made by prosecutor

the government's cross-motion for summary judgment. Consequently, their motion should be denied. DATED: August 25, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Flat No. 0936693 8 EFTA00799971 Case 9:08

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

applied to bar their claims. The government's cross-motion for summary judgment should be granted. DATED: October 6, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY 29 EFTA00800004 Case 9:08-cv-80736-KAM Document 425-1 Entered on FLSD Docket 10/06/2017 Page 31 of 33 By: s/ De

its legal impact as opinion and conclusion, not an assertion of fact. . 39. The Government admits that the NPA provided that, upon its execution, "the United States, in consultation with and subject to the good faith approval of Epstein's counsel, shall 5 EFTA00799785 Case 9:08-cv-80736-KAM Document 407 Enter

-13. /// /// /// 20 EFTA00799800 Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 21 of 22 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suit

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

e. / / / I/I I/I 30 EFTA00799854 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 31 of 32 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suite

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

/ / / / / / / 30 EFTA00591491 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 32 of 33 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suite