Epstein Secrets

CKING FORM Party Filing Matter Under Seal On behalf of (select one): Name: JIM= u.S. Attorneys Office Address: 500 S. Australian Ave: Suite 400, Wesl Palm Beach, FL 33401 Telephone: 0 Plaintiff O Defendant Date sealed document filed: 8/31/2007 If sealed pursuant to statute, cite statute: Fed. R. Grim. P.

ect copy of the forging motion was furnished by facsimile and U.S. mail to: Esq., U.S. Attorney's Office, 500 South Australian Avenue, Suite 400, West-Palm Beach, FL 33401. gC: 44 OS ROY BLACK, ESQ. Counsel for Jeffrey Epstein ?tit Ile...LeneA nein Black srcbmck. Kornsparl & Stumpf EFTA00179082 U.S.

ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF

RRA P-000999 EFTA00228379 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 40', West Palen Beach. FL 33401 (361)8104711 August 15, 2007 Case No. 08-80736-CV-MARRA P-001000 EFTA00228380 Sincerely, R. ALEXANDER ACOSTA STATES ATTO Y By:

an indicate the presence or absence of contraband does not implicate the Fourth Amendment. In United Slates'. Thomas 757 F.2d 1359 (2d. Cir. 1985), the Second Circuit rejected a broad application of this rule. In particular, it held that a dog sniff outside a private residence implicated the Fourth Amendment. The

VVest Palm Beach,- Florida 33401 .4 5 JACK GOLDBERGER,:ESQ. ATTENBURY. GOLDBERGER. RICHARDSON & WEISS, P:A. 6 250 South Australian Avenue, Suite 1400 West Palm Beach'. Florida 33401 7 8 APPEARING ON BEHALF OF WITNESS: 9 JOANNE O'CONNOR, ESQ. JOHN RANDOLPH, ESQ. 10 JONES. FOSTER, JOHNSTON & STUBBS. R:A. 505 South' F

o dozens of victims who were abused in Florida. 2 While beyond the scope of a bail hearing, as discussed further below, it is well-established in the Second Circuit that absent an express provision to the contrary in the agreement, one District is not bound by the terms of an agreement entered into between a defe