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the request of his client..., Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of.. See Complaint, M. I. Epstein, (Exhibit 1"). 47. Jane Doe's federal complaint indicated that she sought damages of more than $50,000,000. 16 EFTA00188881 Case 9:08-cv-807dlin
stein's personal pilot), (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (manager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of someone that would have helpful
vice in the State of Florida. 3. Prior to assuming his teaching responsibilities, PAUL G. CASSELL clerked first for the U.S. Court of Appeals for the D.C. Circuit (1984-1985) and then from 1985 to 1986 clerked for the United States Supreme Court before serving as an Associate Deputy Attorney EFTA00188845 Ca
•ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein said he is awaiting further documents they've requested from the medical examiner, the paramedics and the Bureau of Prisons" to support his contenti
P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of
•ey Epstein Wasn't Trafficking Women — And He Didn't Kill Himself Brother Says, Miami Herald (Nov. 14, 2019), hups://hrld.us/3ibIANJ (noting that "Mark Epstein said he is awaiting further documents they've requested from the medical examiner, the paramedics and the Bureau of Prisons" to support his contenti
P records qualify as law enforcement records. But, as the Government cannot help but acknowledge, courts in this circuit—like the Ninth Circuit and the D.C. Circuit—have squarely rejected that per se approach, instead requiring a rational nexus to enforcement of a federal law. See Human Rights Watch v. Dep't of
Entities connected to both Mark Epstein and the D.C. Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Alan Dershowitz
PERSONLeon Black
PERSON
George W. Bush
PERSON
United States
LOCATION
Bill Clinton
PERSON
New York
LOCATIONJack Goldberger
PERSONJane Doe
PERSONDarren Indyke
PERSONMaria Farmer
PERSON
Jean-Luc Brunel
PERSON
Marc Rich
PERSON
Alfredo Rodriguez
PERSONthe Southern District
LOCATION