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

nt 106 Entered on FLSD Docket 10/10/2011 Page 26 of 27 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Salt Lake City, UT

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

ys to reduce any such burden. DATED: October 3, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale, Florida 33301 Telephone Facsimile Florida Bar No.: E-mail: EFTA00208644 Case 9:08-cv-80736-KAM Document 225-1 Entered o

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. Agars, 427 U.S. 97 (1976)." The Court should adopt that language to the case at hand here. Interesting, the Standing Discovery Order — and assoc

such a responsive document. DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN, P.L. Fort Lauderdale Florida 33301 Telephone Facsimile E-mail: and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the Universi

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

ways to reduce any such burden. DATED: June 24, 2013 Respectfully Submitted, 5/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS FISTOS & LEHRMAN Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah and EFTA00615913 Case 9:08-cv-80736-KAM Document 265-1 Ent

did not apply to Jane Doe #1 and Jane Doe #2 because no federal charges had ever been filed against Jeffrey Epstein. The Court has firmly rejected the United States' position. In a detailed ruling, the Court concluded that the CVRA extended rights to Jane Doe #1 and Jane Doe #2 even though federal charges were n

ket 02/06/2015 Page 19 of 20 DATED: February 6. 2015 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER. JAFFE, WEISSING. EDWARDS FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys, or the victims This daytime business a