Epstein Secrets

Miami Center Miami, ;bride 33131.4325 *Igeepl.n: :Fa. ziroi e: July 9, 2007 As 3i stant US Attorney S00 South Australian Avenue, Suite 400 WI !st Palm Beach, Florida 33401 RE: Grand Jury Subpoena CASE NO. FGJ 07-103(WPB)/No. OLY-64 5501 SW Sunshine Farms Way Palm City, Florida 34990.5696 Telephona

09:28 PM M RS 30' 90189 P.02 U.S. Department of Justice United States Attorney Southern District of Florida 500 g Australian Ave, Suite 400 Ware Palm Beach, FL 11401.6235 APPEARANCE NOTICE The attached subpoena requires the production of the records specified to a Federal Grand Jury/Trial in the South

re the Grand Jury of the United States District t the place, date and time specified below, United States District Courthouse 701 Clematis Street West Palm Bench, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: March 13, 2007 1:00 pm• YOU ARE ALSO COMMANDED to bring with you the following document(s)

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

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

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

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.

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re

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

"it is essential that a lawyer work with a certain r 161 degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510, 67 S. Ct. 385, 91 L. Ed. 451 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a part