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

uct" does not rise to the level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401 (D.C. Cir. 1985) (exception to attorney-client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

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.

Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileg

act disk and was placed into evidence via a property receipt. At 1400 hours, Det. and I went to the Towers Condominium, 1515 Sout agler Drive in West Palm Beach, where the suspect currently resides. I observed several video cameras on the outside of the building and a doorman at the main entrance on the sou

ity of Bellingham 780 P,2d 272, 275-76 (Wash. App. 1989) (collecting cases). See also Bur. of Nat'l Affairs v. U.S. Delft. of Justice 742 F.3d 1484 (D.C. Cir. 1984) (holding that personal appointment materials, such as calendars and daily agendas for the convenience of Assistant Attorney General, are not

2006. Towards the end of 2006, Epstein's attorneys began making contact with the U.S. Attorney's Office to seek resolution of the case. A meeting in West Palm Beach was held with Epstein's attorneys in February 2007. Aftcr that meeting, the investigation continued, and an indictment package was prepared in May 2

09). Courts have long consulted official CRS summariesto assess legislative intent, see, e.g., &nig Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cir. 1984); fIRECI'V Inc. I. Cignarella No. I. Civ.A 03-2384, 2005 W 1252261 at *7 (D.N.J. May 24, 2005); Clokesav St. Francis Hoso. & Healthcare No.

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

e level of conduct that triggers an exception to the work product doctrine. See, e.g., In re Sealed Case, 754 F.2d 395, 401, 244 U.S. App. D.C. 11 (D.C. Cir. 1985) (exception to attorney- client privilege applied where alleged wrongdoing included "perjured testimony, document destruction, and similar mis

try and hide out from Epstein and his co-conspirators for years. From 1999 through 2002, Epstein frequently sexually abused Jane Doe #3, not only in West Palm Beach, but also in New York, New Mexico, the U.S. Virgin Islands, in international airspace on his Epstein's private planes, and elsewhere. Epstein also

by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey I. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"