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.

position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot

nd finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. (See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern I. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

DE 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6ih day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA00210164 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Detail of Privilege an

position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot

and finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. L DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

E 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 611' day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA_R1_0 1293460 EFTA02335922 Case 9 08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Det

position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot

nd finds that the Government has submitted sufficient evidence to evaluate its claims of privilege. (See DE 238-1) (discussing documents prepared by the United States Attorney's Office in anticipation of possible Epstein prosecution); see Stern v. O-Quinn, 253 F.R.D. 663, 675 (S.D. Fla. 2008) (Rosenbaum, Mag. J.)

DE 268 is hereby UNSEALED. DONE AND ORDERED in chambers at West Palm Beach, Palm Beach County, Florida, this 6ih day July, 2015. KENNETH A. MARRA United State District Judge 25 EFTA01657776 Case 9:08-cv-80736-KAM Document 330 Entered on FLSD Docket 07/06/2015 Page 26 of 51 TABLE Detail of Privilege an

position that the work-product immunity applied only to documents prepared in direct relation to the case at bar," 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 518 (3d ed. 2010), more recent cases "have generally found that documents produced in anticipation of litigating one case remain prot

nexplicably poor decision when it decided not to prosecute Epstein. "[T]he Government retains 'broad discretion' as to whom to prosecute." Wayte v. United States, 470 U.S. 598, 607, 105 S. Ct. 1524, 84 L. Ed. 2d 547 (1985). The CVRA incorporates this principle, providing that "[n]othing in this chapter shall

subsequent litigation." 462 U.S. 19, 25, 103 S. Ct. 2209, 76 L. Ed. 2d 387 (1983) (emphasis in original); see also 8 Wright, Miller & Marcus, Fed. Prac. & Fed. P. § 2024, p. 519 n.47 (3d ed. 2010) (collecting cases). Similarly, the work-product doctrine applies regardless of whether litigation actually en