Epstein Secrets

P-003745 EFTA00086415 EISENBERG & FOUTS, P.A. ATTORNEYS AT LAW JAMES L. EISENBERG Suitt 704. Oat Cleartake Centre 250 Australian Avenue So. Wen Palm Beach. FL 33401 BOARD CERTIFIED CRIMINAL TRIAL LAW5'ER 561-659-2009 Fax Case No. 08-80736-CV-MARRA P-003746 EFTA00086416 EISENBERG & FOUTS, P.A. A

ry Material and the Order granting same shall be provided to counsel for the United States. DONE AND ORDERED in chambers this day of May, 2017, at West Palm Beach, Florida. DANIEL T. K. HURLEY SENIOR UNITED STATES DISTRICT JUDGE cc: AUSA EFTA00086376 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLO

"work-product doctrine is distinct from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

NY; Martin G. Weinberg, PRO HAC VICE, Martin G. Weinberg, P.C., Boston, MA. For Bruce Reinhart, Intervenor: Bruce Reinhart, McDonald Hopkins, LLC, West Palm Beach, FL. For internal use only SDNY_GM_00059569 CONFIDENTIAL - PURSUANT TO FED. R.QC;IN(F IDENTIAL DB-SDNY-0022393 EFTA_001701 19 EFTA01296787 Pa

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply

t Jeffrey Epstein (a billionaire with significant with significant political connections) sexually abused more than 30 minor girls at his mansion in West Palm Beach (sic), Florida, and elsewhere. Epstein performed repeated lewd, lascivious, and sexual acts on them, including (but not limited to) masturbation, to

f litigation.' United States' Nobles, 422 U.S. 225, 238 (1975). The work-product doctrine applies in civil and criminal litigation. Id. at 236. In Hickman' Taylor, the Supreme Court described the policy behind the doctrine protecting the opinion work-product of lawyers. The Court explained that a lawye