Epstein Secrets

proof beyond a reasonable doubt that each of them was a victim of an enumerated offense." (emphasis added). First Assistant United States Attorney Jeffrey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to M

frey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see gim your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains

as well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and t like.") (citing Dug Dow Jones & Co., Inc„ 142 F.3d 496, 500 (D.C. Cir. 1998)); see also SEC Dresser Indust. la, 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't Nat'

proof beyond a reasonable doubt that each of them was a victim of an enumerated offense." (emphasis added). First Assistant United States Attorney Jeffrey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to M

frey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lelkowitz at 2, 3; see gla your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 p.m., where you state that the list contains

well as actual transcripts, the strategy or direction of the investigation, the deliberations or questions of jurors, and the like.") (citing In.m Dow Jones & Co., Inc.„, 142 F.3d 496, 500 (D.C. Cir. 1998)); see SEC v Dresser Indust'. Inc., 628 F.2d 1368, 1382 (D.C. Cir. 1980); Fund for Constitutional Gov't v

States believes it has proof beyond a reasonable doubt that each of them was a victim of an enumerated offense." (emphasis added). First Assistant Jeffrey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr

ffrey Sloman used similar language in tying the names of the "victims" to the basis for a potential indictment, see December 6, 2007 letter from Mr. Sloman to Mr. Lefkowitz at 2, 3; see also your email to Mr. Lefkowitz and Mr. Black on August 14, 2008 at 3:27 PM, where you state that the list contains

s that either testified or were identified during Grand Jury proceedings are subject to the secrecy provisions of F.R.Crim.P 6(e). Ste, tg,,, In re Dow Jones & Co., Inc., 142 F.3d 496, 500 (D.C. Cir. 1998) ("Consistent with these purposes, we have recognized that grand jury secrecy covers `the identities of wit

te Burnett F OWL E RWH I T E All'otiNgTS AT LAW B URNETT MIAMI • F00 LAUDERDALE • WraT PALM UfA01 • 5T. PETER5OLMO 3067800201 December 7, 2007 Jeffrey Sloman First Assisiam United States Attorney United Stales Attorney's Office Southern District of Florida Re: Jeffrey Epstein Dear Jeff: 1-(466 P.002

statute. I would note that the United States provided the draft letter to defense ns a courtesy. in addition, First Assistant United States Attorney Sloman already incorporated in the letter several edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of proceed

ve disclosures of grand jury material, "Rule 6(e) does not create a type of secrecy which is waived once public disclosure occurs." In re Motions of Dow Jones & Co., 142 F.3d 496, 505 (D.C. Cir. 1998) (quoting In re North, 16 F.3d 1234, 1245 (D.C. Cir. 1994)). "[Elven if material concerning the grand jury inves