Epstein Secrets

14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. then known as Jane Doe Number

o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono

that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation case there is more latitude to introducing 6 reputational types of evidence. However, it's important to

UTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794625 71 H3V0GIU1 1 so let meet respond to that overview. 2 They reference Mueller and Kirkpatrick, a treatise 3 that we think is very instructive on this particular point. 4 Mueller and Kirkpatrick says, "It is true that in a 5 defamation ca

14 Let me turn then to point number 19. Here again, we 15 have a narrow issue presented to your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Honor is well aware, the triggering event in this case 18 was when Ms. , then known as Jane Doe Numbe

o your Honor. We are asking 16 that you exclude Judge Marra's ruling on the joinder motion. 17 As your Hono

spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there is more latitude to introducing reputational types of evidence. However, it's important to remem

7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3V0GIU1 -1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that in a defamation case there

you already. Let me turn then to point number 19. Here again, we have a narrow issue presented to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is well aware, the triggering event in this case was when Ms. Giuffre, then known as Jane Doe Number 3,

ed to your Honor. We are asking that you exclude Judge Marra's ruling on the joinder motion. As your Honor is

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 val H3VOGIU1 so let meet respond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there i

spond to that overview. They reference Mueller and Kirkpatrick, a treatise that we think is very instructive on this particular point. Mueller and Kirkpatrick says, "It is true that ina defamation case there is more latitude to introducing reputational types of evidence. However, it's important to rememb

Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to t

and Roy Black; cc: Gerald Lefcourt, John McMillan, Karen Atkinson, and Andrew Lourie . Jay Lefkowitz Response to email that Jenny from Judge Marra's office spoke with the Judge and he agreed to take the matter off the calendar. If a plea agreement is reached, USAO will withdraw the subpoena an

ceeding conducted by the Justice Department's Office of Professional Responsibility (OPR) arising out of a decision by United States District Judge Kenneth A. Marra in the matter of Jane Doe 1 and Jane Doe 2I United States, S.D. Fla. Case No. 08-80736-Civ-Marra; (3) the materials are needed to avoid an injusti

s advice on some of the issues — legal and non-legal — that arose during the case. Assistant U.S. Attorney Lynn Kirkpatrick (still at the USAO): Ms. Kirkpatrick and I are friends from my time in Miami. She was a supervisor in Miami although not in my chain of command. I would often speak or email with her j

0 S. Australian Ave, Suite 400 1290 08-80736-CV-MARRA P-014772 EFTA00189391 West Palm Beach, FL 334

From: Villafana. Ann Marie C. (USAFLS) Sent: Thursday, March 20, 2008 4 18 PM To: Kuyrkendall, E N . Richards. Jason R Senior. Robed (USAFLS). Kirkpatrick. Lynn (USAFLS) Subject: FW: Follow up FYI — Bob, you probably already received this from JetT, but just in case. And Jason and Nesbitt, here is th

7 Fax 561 820-8777 Tracking: 1121 08-80736-CV-MARRA P-014869 EFTA00225273

Villafana, Ann Marie C. (USAFLS) From: Villafana, Ann Marie C. (USAFLS) Sent: Tuesday, April 22.2008 12:19 PM To: 'Kuyrkendall. E N.': Kirkpatrick. Lynn (USAFLS) Subject: So So, I was sitting at the doctor's office yesterday waiting for my appointment and I started reading Oprah's magazine.