Epstein Secrets

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

ry orders, Epstein's attorneys secretly withheld significant correspondence involving plea discussions by several of Epstein's attorneys, including Lillian Sanchez, Jay Lefkowitz, and Ken Starr. If this is true, as part of any privilege log they file, the defense attorneys should explain why they secretly and

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[Tjhe United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ernment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and asso

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00179727 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 30 of 64

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00208636 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 30 of 64

this 19th day of July, 2013, on the parties and counsel appearing on the attached service list. 11 EFTA00208785 SERVICE LIST Jane Does 1 and 2 I. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Paul G. Cassell Martin G.

ve process privilege. 3 EFTA00208777 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (f) Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe #1

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search foi that information." DE

ormer President Bill Clinton, Andrew Albert Christian Edward (a/k/a Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Elt tefkowitz, and Roy Black on his behalf. EFTA00615897 Case 9:08-cv-80736-KAM Document 265-1 Entered on FLSD Docket 10/20/2014 Page 30 of 64

counsel appearing on the attached service list. /s Dexter A. Lee Assistant United States Attorney II EFTA00191209 SERVICE LIST Jane Does 1 and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing,

ve process privilege. 3 EFTA00191201 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe # I

port of its motion to stay. DE 140. In that reply, the Government represented that it would voluntarily be providing information to the victims: "[T]he United States has agreed to provide some information to [the victims] even during the pendency of the stay and is undertaking a search for that information." DE

former President Bill Clinton, Andrew Albert Christian Edward (aAda Prince Andrew, Duke of York), Harvard Law Professor Alan Dershowitz, Ken Starr, Lillian Sanchez, Jay Lefkowitz, and Roy Black on his behalf. EFTA00081144 Case 9:08-cv-80736-KAM Document 225-1 Entered on FLSD Docket 08/16/2013 Page 30 of 64

DISTRICT OF FLORIDA Case No. 08-80736-CIV-Marra/Matthewman JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Do

SDakelte702011XCIMEPailigt fef (112 13 6. (a) Denied. (b) Denied. (c) Admitted. (d) Admitted. (e) Admitted to the extent that the reference to "Lillian Sanchez" was meant to refer to Lilly Ann Sanchez. (0 Admitted. (g) Admitted. 7. The government admits that, on about January 10, 2008, when Jane Doe #1 a