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ding all discovery) provided to you by the State Attorney's Office, and/or Palm Beach County Police Department and/or U.S. Attorney's Office and/or the Federal Bureau of Investigation relating to the Defendant, JEFFREY EPSTEIN. Response: Defendant is asserting specific legal objections including but not limited to relying on cer
Circuit has recently refused to extend the act of production doctrine to facts very similar to those here. In United States v. Ponds, 454 F.3d 313 (D.C. Cir. 2006), federal prosecutors sought information about possible crimes committed by a defense attorney in the course of representing a defendant in a
ised of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified. F2 Epstein's counsel is correct, however, i
ry Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege
ised of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified. F2 Epstein's counsel is correct, however, i
ury Matter No. 91-01386 , 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States I Legal Servs. for New York City , 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privilege
, § 2252A(a)(I), § 2252A(g)(I), and * 1591. 23. After investigations by the Palm Beach Police Department, the Palm Beach State Attorney's Office, the Federal Bureau of Investigation, and the United States Attorney's Office for the Southern District of Florida, Defendant, Jeffrey Epstein, entered picas of "guilty" to various Flo
09). Courts have long consulted official CRS summariesto assess legislative intent, see, e.g., &nig Pension Ben. Guar. Com. 744 F.2d 133, 145 & n.7 (D.C. Cir. 1984); fIRECI'V Inc. I. Cignarella No. I. Civ.A 03-2384, 2005 W 1252261 at *7 (D.N.J. May 24, 2005); Clokesav St. Francis Hoso. & Healthcare No.
Danielle Ivory, In Short-Staffed Jail, Epstein Was Left Alone for Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019), https://nyti.ms/2F9mXzs. The Federal Bureau of Investigation, the Department of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has sugges
the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim
Danielle Ivory, In Short-Staffed Jail, Epstein Was Left Alone for Hours; Guard Was Substitute, N.Y. Times (Aug. 12, 2019), https://nyti.ms/2F9mXzs. The Federal Bureau of Investigation, the Department of Justice's Inspector General, and the Bureau of Prisons itself all launched investigations. For his part, the President has sugges
the Air Force, 566 F.2d 242 (1977) 6 Meyer v. Bush, 1991 U.S. Dist. LEXIS 13626 (D.D.C. Sept. 30, 1991), rev'd on other grounds, 981 F.2d 1288 (D.C. Cir. 1993) 7 Morley v. C.I.A., 508 F.3d 1108 (D.C. Cir. 2007) 14 Multi Ag Media LLC v. Dep't ofAgric., 515 F.3d 1224 (D.C. Cir. 2008) 14 N.Y. Tim
f which do not carry a statute of limitations and thus are not time-barred. See 18 U.S.C. § 3283. And these offenses were the kinds of offenses that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office for the Southern District of Florida were pursuing in 2007. So far as Jane Doe #4 is aware, the U.S. Attorney's Off
by a grand jury investigating possible criminal violations is not part of a 'civil action.'"); Blair-Bey I. Quick, 151 F.3d 1036, 1039 (D.C. Cir.) (D.C. Cir. 1998) ("the courts have uniformly concluded that habeas corpus proceedings — and their cousins, section 2255 proceedings — are not 'civil actions"
sed of the scope of the federal grand jury investigation, which is broader than the state investigation. The federal investigation, as conducted by the Federal Bureau of Investigation ("FBI"), is broader both in terms of the crimes being investigated and the number of victims identified' Epstein's counsel is correct, however, in
Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that "[c]ourts have consistently held that the general subject matters of clients' representations are not privileg
omplaint, Jane Doe No. 102' Epstein, No. 9:09-CV-80656- KAM (S.D. Fla. May 1, 2009). 3. In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of Investigation opened an investigation into allegations that Jeffrey Epstein and his personal assistants had used facilities of interstate commerce to induce young
of the final decision of the Attorney General" of any complaints of violations of the CVRA. Block v. Securities and Exchange Comm In, 50 F.3d I078 (D.C. Cir. 1995), is instructive. In Block, petitioners filed a petition asking the Court to find that the SEC had failed to fulfill its obligation to hold a
Entities connected to both FBI and D.C. Cir

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
Ghislaine Maxwell
PERSON
Alexander Acosta
PERSON
Prince Andrew
PERSONLeon Black
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Scarlett Johansson
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION
Southern District of New York
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Julie K. Brown
PERSON