Epstein Secrets

[email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston. MA 0211

1 (305) 358-2006 Jay P. Leflcowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza Suite 1000 Boston. MA 02116 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley J. Edwards 9 EFTA00208681

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product

oy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly

in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but n

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

Deposition, Ex. 3 (Doc. # 223-3). Plaintiff fails to explain her strategic decision, or negligence, in failing to respond for over six weeks to Mr. Weinberg's email offering to accept service. Indeed, in another failure of candor, Plaintiff's counsel also neglected to tell this Court about the email offe

her motion to serve Mr. Epstein by alternate means. Mot. at 2; Doc. # 160.8 Plaintiff apparently now claims that she never received that email from Martin Weinberg. All of the preceding communications, however, indicate that Mr. Weinberg promptly responded to Ms. McCawley's inquiries. See, e.g., Poe Declaratio

that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions. Mr. Rizzo, in fact, was practically gleeful to be a witness: Doc.

in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but n

oy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

. Proud Boy Who Helped Ignite Capitol Breach Tells Jury He Got "Caught Up" in Jan. 6 Chaos Politico (04/18, Cheney) and the Washington Post (04/18, Weiner) reported that Dominic Pezzola, a member of the Proud Boys who helped to fuel the breach of the Capitol on Jan. 6, testified on Tuesday that he simp

guardrails to deter repeat offenses." Trump Could Be Banned From Ever Entering White House Again Using Civil War-Era Clause The Independent (04/18, Feinberg) reported that two nonprofit groups, Free Speech for People and Citizens for Responsibility and Ethics in Washington, are preparing to challenge Don

ori), The Guardian (04/18, Singh), Axios (04/18, Fischer), Fox News (04/18, Wulfsohn), BBC News (04/18, Debusmann), CNBC (04/18, Mangan, Breuninger, Rizzo), Al Jazeera (04/18, Staff Writer), ABC News (04/18, Katersky, Rubin), Rolling Stone (04/18, Bort, Legaspi), The Intercept (04/18, Maass), Business

in the Epstein investigation) and defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but n

oy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

oy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly

om (305) 37106421 Jay P. Lefkowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Email: [email protected] (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley

ion against any public interest in non-disclosure. That balancing process is ordinarily made with reference to factors discussed in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D.Pa.1973), specifically: (1) the extent to which disclosure will thwart governmental processes by discouraging citizens fr

m (305) 37106421 Jay P. Leflcowitz Kirkland & Ellis, LLP 601 Lexington Avenue New York, NY 10022 Email: [email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 02116 Email: [email protected] (617) 338-9538 Criminal Defense Counsel for Jeffrey Epstein /s/ Bradley

[email protected] (212) 446-4970 Martin G. Weinberg, P.C. 20 Park Plaza, Suite 1000 Boston, MA 0211

Tuite v. Henry, 98 F.3d 1411, 1418 (D.C. Cir. 1996). The balancing is ordinarily made by considering the ten factors identified in Frankenhauser v. Rizzo, 59 F.R.D. 339, 344 (E.D. Pa. 1973). Those ten factors decisively tip in favor of the victims receiving access to the information. D. Work Product

f 2010, two attorneys in the Justice Department — Marty Lederman and David Barron — had authored a secret

embedded in different services, including those designated as "clandestine" and "forward deployed." When the agency wants to launch a drone strike, Rizzo explained in an interview with Newsweek, it asks a lawyer to provide legal cover for the assassination by signing off on a five-page dossier laying

the existence of cancer, the personal testimony of the lay sufferer is entitled to no weight...... 4I Furthermore, as the Supreme Court found in Weinberger v. Hynson, Westeott and Dunning, Ine.,43: (FDA's] strict and demanding standards, barring anecdotal evidence indicating that doctors "believe" in

s unquestionably protected from unwarrant- generally only permitted in "extraordinary ed interference by prosecutorial officials; circumstances," Rizzo v. Goods, 423 U.S. whether the investigation actually involved 362, 379, 96 S.Ct 598, 608, 46 L.Ed2d 661 any unwarranted intrusions into their sat