Epstein Secrets

etter to Mr. Goldberger that "the U.S. Attorney's modification of the 2255 portion of the Agreement now limits our victim list to those persons whom the United States was prepared to include in an indictment. This means that, pursuant to Justice Department policy, these are individuals for whom the United States b

other instances where 5 counsel other than myself, not in the civil aspects, where 6 allegations have been made and letters have been sent by the 7 United States suggesting that there's been a violation of the 8 NPA. And under those circumstances, some notification was 9 provided. 10 THE COURT: Did it have

21 until 37:23 urge 22:9 use 10:25 11:8 20:24 23:1128:25 40:11 used 28:19 U.S 2:15 4:10 7:1,9 8:6 12:8,12 16:16 26:19 27:4,18,19 43:5,11,25 U.S.A 2:16 U.S.0 33:7 I various 3:1 10:25 very 4:21 5:711:1,2 1120 12:21 16:19 162417:12,12 23:1129:4 32:1 35:18 38:10 40:18 42:2 43:18 44:14 Via

were identified dining Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). S,g, e.g., In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witnes

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

ings, 616 F.3d 1172 (10° Cir. 2010). 2 "Grand jury secrecy is not unyielding" when there is no secrecy left to protect. In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006). Rule 6(e)(6) requires that records, orders and subpoenas relating to grand jury proceedings remain sealed onl

erms of the Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides you with notice that the United States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated one of the conditions of the Non-Prosecution Agreem

ty agreement between your Office and Mr. Epstein as well as the provisions of Fed. R. Crim. P. 6(e). As to the NPA, you have repeatedly asserted in Doel United States No. 9:08-ev-80736- KAM, that the NPA was a confidential document. For instance, in paragraph 6 of Document 14, your own Declaration, you stated that

were identified during Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). Sys, e.z., In re Grand Jury Subpoena, Judith Miller 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witness

ator Feinstein)(explaining that the right to confer was "intended to be expansive," applying to "any critical state or disposition of the case") and United States v. Heaton, 458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of using facility of interstate commerce to entice minors to enga

ted States of America. (Lee, Dexter) (Entered: 01/26/2012) 01/26/2012 .1.44 RESPONSE in Opposition re_12$ Motion for Miscellaneous Relief filed by United States of America. (Sanchez, Eduardo) (Entered: 01/26/2012) 01/27/2012 145 ENDOR ingitl Motion for Leave to File Excess Pages. Signed by Judge on 1/27/2012. (ir)

ings, 616 F.3d 1172 (10° Cir. 2010). 2 "Grand jury secrecy is not unyielding" when there is no secrecy left to protect. In re Grand Jury Subpoena, Judith Miller, 438 F.3d 1138, 1140 (D.C. Cir. 2006). Rule 6(eX6) requires that records, orders and subpoenas relating to grand jury proceedings remain sealed only

ess in the South China Sea could compromise its claim to a peaceful rise and reinforce the call from countries like Vietnam and the Philippines for the United States to step up its military presence in the region. Perhaps the most important step the United States can take in EFTA_R1_00228287 EFTA01841751 the

l succeeds in short-term air strikes, Iran is willing and able to cause and promote instability in the region. This is in direct contradiction with the United States' broad interest in the Middle East, which is stability. - Iran may not be able to keep the Strait of Hormuz closed indefinitely, but even threats a

lingness to endure withering castigation for his own views. In return, he skewers many people — Thomas Friedman, David Brooks, Michael Mandelbaum, Judith Miller, Leon Wieseltier, Michael Ignatieff, myself included — for being ignorant at best and willing dupes of power at worst, never conceding that his opp

terms ofthe Non-Prosecution Agreement, the United States Attorney's Office for the Southern District of Florida hereby provides you with notice that the United States Attorney has determined, based on reliable evidence, that Jeffrey Epstein has willfully violated one of the conditions of the Non-Prosecution Agreem

r were identified during Grand Jury proceedings are subject to the secrecy provisions of Fed. R. Crim. P. 6(e). age, gg„ In re Grand Jury Subpoena, Judith Miller 438 F.3d 1138, 1140 (D.C. Cir. 2006) ("Consistent with these purposes, we have recognized that grand jury secrecy covers 'the identities of witness

cceeds in short-term air strikes, Iran is willing and able to cause and promote instability in the region. This is in direct contradiction with the United States' broad interest in the Middle East, which is stability. - Iran may not be able to keep the Strait of Hormuz closed indefinitely, but even threats an

llingness to endure withering castigation for his own views. In return, he skewers many people — Thomas Friedman, David Brooks, Michael Mandelbaum, Judith Miller, Leon Wieseltier, Michael Ignatieff, myself included — for being ignorant at best and willing dupes of power at worst, never conceding that his opp