Epstein Secrets

ccessible through multiple websites, the Government has elected to produce a copy to you as a courtesy. In addition, due to an inadvertent error in Bates stamping in the prior production, which the Government just discovered, we are reproducing certain of the materials in the below index. These items

the Government just discovered, we are reproducing certain of the materials in the below index. These items were originally produced with incorrect Bates numbers that resulted in overlaps. These errors have now been corrected. These discovery materials are now stamped with the correct control numbers

l report of the Office of Professional Responsibility ("OPR") regarding the resolution of the 2006-2008 criminal investigation of Jeffrey Epstein by the U.S. Attorney's Office for the Southern District of Florida (the "OPR Report"). Although the OPR Report is publicly available and accessible through multiple websites, the

are not aware of any authority requiring us to obtain and/or disclose this information. Request 11 — A Complete, Unredacted Copy of FBI 302 Bearing Bates Numbers SDNY_GM_00114982-00114993: The Government has produced this particular version of the document in the form in which it received the documen

r disclosure obligation. Nor is the Government aware of any basis in law for this request. We note, in this respect, that neither the defendant nor the U.S. Attorney's Office for the Southern District of New York is a party or signatory to the NPA, nor is the defendant or this Office named therein. As noted in the Govern

do not constitute Giglio or Jencks Act material. Request 14 — All Written and Oral Communications and Other Documents Concerning Meetings between the United States Attorney's Office for the Southern District of New York and Specified Attorneys for the Minor Victims and Other Witnesses: Your request does not articulate a basis i

ons between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative ag

tember 24, 2007. Such communications include: a. All communications between the government — including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prose

0. See SDNY GM 00165982-00162988.i II. We request a complete, unredacted copy of the FBI 302 produced by the government on August 13, 2020, bearing Bates numbers SDNY_GM_00114982-00114993. 12. We request that the government produce all versions and drafts of the book/memoir "The Billionaires Playboy

processed prior to July 2019 consecutively as "03956-1 through 03956-11571." These records are referred to in this declaration collectively as the Bates-stamped or Bates-numbered records.' I On the pages released in full or in part, these " In contrast, records processed after July 2019 were not Bate

satisfies Exemption 5's threshold of being inter-agency because these records were exchanged within Department of Justice (i.e., between the FBI and U.S. Attorney's Office). Furthermore, these records are quintessential attorney work products and readily satisfy the elements of the attorney work product privilege beca