Epstein Secrets

Herman & Mennelstein, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Re: Jeffrey Epstein/ FIFICATION OF IDENTIFIED VI Dear Mr. Herman: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to y

right to contest liability and also waives his right to contest damages up to an amount as agreed to between Ms. nand Mr. Epstein, so long as Ms. Cavallaro elects to proceed exclusively under 18 U.S.C. § 2255, and she waives any other claim for damages, whether pursuant to state, federal, or common law

or his counsel [would] pursue [plea negotiations] if the remarks uttered during the course of it are to be admitted in evidence as proof of guilt." Herman, 544 F.2d at 797. Plea negotiations are "rooted in the imperative need 22 EFTA00177961 Case 9:08-cv-80736-KAM Document 94 Entered on FLSD Docket

STANDARD OF REVIEW [23[3] On an appeal concerning a claim of privilege, the standard of review de- pends on the pgcise issue being litigated. See Cavallaro . United States, 284 F. 236, 245 (1st ir.2002); United States I Mass. Inst. of Tech., 129 F.3d 681, 683 (1st Cir.1997). We review rulings on quest

Herman & Mennelstein, P.A. 18205 Biscayne Boulevard Suite 2218 Miami, Florida 33160 Re: Jeffrey Epstein/ TIFICATION OF IDENTIFIED VI Dear Mr. Herman: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following notice to y

right to contest liability and also waives his right to contest damages up to an amount as agreed to between Ms. nand Mr. Epstein, so long as Ms. Cavallaro elects to proceed exclusively under 18 U.S.C. § 2255, and she waives any other claim for damages, whether pursuant to state, federal, or common law