Epstein Secrets

gs with the Florida Division of Corporations and/or the Florida Bar. On 08, at approximately 1:15 pm, I received a call from Jeffrey Herman of . Herman said that he was planning to file a civil lawsuit the next Confidential and Privileged— Attorney Work Product -12- EFTA00224647 week against Jeff

dy, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 1

ly to discuss his or her situation in order to explore the possibility of disposing of the case through a consensual arrangement." United States v. Herman, 544 F.2d 791, 797 (5th Cir. 1977). The Rule is derived from "the inescapable truth that for plea bargaining to work effectively and fairly, a defen

matters. Thus, when once- secret grand jury material becomes "sufficiently widely known," it may "los[e] its character as Rule 6(e) material." In re North, 16 F.3d 1234 (D. C. Cir. 1994). 3 EFTA00177809 Case 9:08-cv-80736-KAM Document 187 Entered on FLSD Docket 06/18/2013 Page 4 of 4 It is accordin

work effectively and fairly, a defendant must be free to negotiate without fear that his statements will later be used against him." United States' Herman, 544 F.2d 791, 796 (5th Cir. 1977). The candor and meaningful dialogue that bring about settlements would be impossible if either party risked havi

type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co.. 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[Elven if material concerning the grand jury investigation had been disclosed to the public, the Government

ions and/or the Florida Bar. On Friday, January 18, 2008, at approximately 1:15 pm, I received a call from Jeffrey Herman of Herman & Mermelstein. Herman said that he was planning to file a civil lawsuit the next Confidential and Privileged — Attorney Work Product -12- EFTA00225189 r • week agains

dy, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. 11/4 > Pursuant to

rmer law partner, has tiled several civil lawsuits against Mr. Epstein on behalf of the alleged "victims." ft is our understanding that each of Mr. Herman's clients arc on the EFTA00225684 UO/V4IV9 sun CAA OVO 00V O1%V 05/28/2008 00:09 FAX 2026161230 DA VON 13:24 KAX 1 :13 660 6500 LSGVUAAVD Ur

dy, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 1