Epstein Secrets

8-80381, 08-80993, 08-80994 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,PL

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

AL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM (DE 431) AND DEFENDANT EPSTEIN'S MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM AS TO JANE FOE NO.4 (DE 443) Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Notice

18205 Biscayne Boulevard 3 Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL

ompel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe No. 4, and states: I. On Dec

77 [email protected] Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman,PL

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

ted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

d by facsimile (561) 802-1787, and U.S. mail to: Maria Villifana, Esq., U.S. Attorney's Office, 500 uth

ry Subpoena dated April 9, 1996, 87 F.3d 1198, 1200 (11th Cir. 1996); United States v. Gecas, 50 F.3d 1549, 1566 (11th Cir. 1995); In re Grand Jury Subpoena Duces Tecum, 754 F.2d 918, 921 (11th Cir. 1985) ("the act of production alone can constitute self-incriminating testimony); In re Grand Jury 83-8, 611 F. Supp.

etitioner: Bradley James Edwards, LEAD ATTORNEY, Farmer Jaffe Weissing Edwards Fistos & Lehrman PL, Fort

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure

mental ambiguity," however, "is the exception, not the rule." United States v. Sarwari, 669 F.3d 401, 407 (4th Cir. 2012) (quoting United States v. Farmer, 137 F.3d 1265, 1269 (10th Cir. 1998)). A defendant cannot demonstrate fundamental ambiguity simply by showing that words used in a question are ame

the proper remedy.38 Indeed, none of the Second Circuit cases applying Martindell contemplate suppression as a remedy. See, e.g., In re Grand Jut), Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d at 1224 (remanding for findings "on whether the protective order was improvidently granted or whether the government

Fax: Jane Doe No. 7 Consol Plaintiff Jane Doe Consol Plaintiff C.M.A. Consol Plaintiff Adam D. Horowitz LEAD ATTORNEY;ATTORNEY TO BE NOTICED Farmer. Jaffe. Weissina, Edwards, Fistos. Lehrman. P.L. 425 North Andrews Avenue Suite 2 Fort Lauderdale , FL 33301 A Fax: Jeffrey Marc Herman LEAD AT

Exhibit A)(Horowitz, Adam) (Entered: 12/21/2009) 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachm

tted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

tionships" and that "[t]his principle has been applied to fiduciary relationships beyond the traditional trust context"); see also In re Grand Jury Subpoena Duces Tecum, 112 F.3d 910, 919-21 (8th Cir. 1997) (government attorneys have duty to report wrongdoing). Communications Facilitating Crime-Fraud-Misconduct Not

Attorneys Bradley James Edwards [COR LD NTC] Farmer Jaffe Weissing Edwards Fistos 8. Lehrman PL 425

orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme