Epstein Secrets

and placed in the public portion of the court file O Destroyed 0 Returned to the party or counsel for the party, as identified above A`tancy for: United Stales of Vifierica EFTA00179092 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND

ry on September 18, 2007. However, 'Witness William Riley did not file an initial motion to quash the grand jury subpoenas, but did file a Reply to the United States' Response to the Intervenor's Motion to Quash. Accordingly, the United States has not previously had the opportunity to respond to the issue raised b

vestigation of these crimes involving the sexual exploitation of minors. The Supreme Court has routinely recognized the grand jury's unique role in the United States' criminal justice system. The grand jury "belongs to no branch of the institutional Government, serving as a kind of buffer or referee between the Go

FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNDER SEAL ORDER THIS CAUSE came before the Court on the United States of America's Motion for Permission to File a supplemental Ex Parte Affidavit in support of its Response to the Motion to Quash. Upon review of the motion, it i

84 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNITED STATES' SURREPLY TO REPLIES FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO OUASH GRAND JURY SUBPOENAS UNDER SEAL EFTA0017908

's command for the production of computers, as if all it wanted was possession of the physical items themselves. For example, the government wishes the "Court to proceed on the manifestly erroneous assumption that the subpoenas are "narrowly tailored" to seek only the "physical computers removed from Epst

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (.5th Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule

ided only against "adversaries." Thus, disclosure of the material to an adversary, real or potential, works a forfeiture of work product protection. United States v. Massachusetts Institute of Technology, 129 F.3d 681 (1" Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's

Case No. 08- 80893-CIV-MARRA. By order entered January 5, 2011 in that proceeding, Magistrate Judge Johnson expressly rejected Epstein's request for the "Court to find the subject correspondence privileged and on that basis prohibit plaintiff? counsel from disclosing it in either of the two 'Fed. R. Crim.

Case 9:08-cv-80736-KAM Document 188 Entered on FLSD Docket 06/18/2013 Page 5 of 11 proceedings against the defendant making them under Rule 410. See e.g United States v. Paden, 908 F.2d 1229, 1235 (5ih Cir. 1990)(statements made during negotiations that resulted in a final plea of guilty not protected under Rule

ided only against "adversaries." Thus, disclosure of the material to an adversary, real or potential, works a forfeiture of work product protection. United States v. Massachusetts Institute of Technology, 129 F.3d 681(1" Cir. 1997). In this case, Epstein's attorneys' disclosure to the United States Attorney's

Case No. 08- 80893-CIV-MARRA. By order entered January 5, 2011 in that proceeding, Magistrate Judge Johnson expressly rejected Epstein's request for the "Court to find the subject correspondence privileged and on that basis prohibit plaintiffs' counsel from disclosing it in either of the two 'Fed. R. Crim.

egral role in helping to establish the Epstein Victim's Compensation Fund, which was one of the largest and most successful claims fund programs in U. S. history. Ms. Henderson has been recognized repeatedly as a "Rising Star" by SuperLawyers and annually by the National Trial Lawyers Association's "T

as the mediator in connection with the proposed settlement of the above- referenced action, entitled Jane Doe v. JPMorgan Chase Bank N.A., pending in the United States District Court for the Southern District of New York. 6. I have set forth my background as a mediator to provide context for the comments that foll

ITIGATION The Litigation is currently pending before Judge Jed S. Rakoff in the United States District Court for the Southern District of New York (the "Court"). The initial complaint in this action was filed on November 24, 2022, and JPMC moved to dismiss the initial complaint on December All capitalized

or New York, New York 10022 (212) 336-8330 Counsel for Claimants Kramer Levin Naftalis & Frankel LLP By: Stephen M. Sinaiko 1177 Avenue of the Americas New York, New York 10036 (212) 715-9100 Freshfields Bruckhaus Deringer US LLP By: Marshall H. Fishman Gabrielle L. Gould 520 Madison Avenue, 3

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th

6-3880 DIRECT On FAX (71 31 654.6686 E-MAIL issus.,450s.A.004wArce.om Stephen M. Sinaiko KRAMER LEVIN NAFTAILIS & FRANKEL LLP 1177 Avenue of the Americas New York, New York 10036 Re: Settlement of Financial Trust Company, Inc. et al v. The Bear Stearns Companies, Inc., et al, FINRA No. 09-00979 De

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th

or New York, New York 10022 (212) 336-8330 Counsel for Claimants Kramer Levin Naftalis & Frankel LLP By: Stephen M. Sinaiko 1177 Avenue of the Americas New York, New York 10036 (212) 715-9100 Freshfields Bruckhaus Deringer US LLP By: Marshall H. Fishman Gabrielle L. Gould 520 Madison Avenue, 3

transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearns Companies Inc., No. 10 Civ. 1226 (RWS) (S.D.N.Y.) (the "Action"), and, by order of th