Subject: Re: Mark Epstein
Summary
From: To: ' Cc: ' Subject: Re: Mark Epstein Date: Mon, 28 Oct 2019 22:19:07 +0000 What will? My client is flying in from Florida based on our original conversation. From our discussion you said 10/31 and I called him immediately. Sent from my iPhone On Oct 28, 2019, at 6:02 PM, > wrote: No, that won't work for us unfortunately. From: Sent: Monday, October 28, 2019 6:00 PM To: Cc: Subject: Re: Mark Epstein I am sorry I would not have confirmed for today. I had a 4 pm doctors appointment scheduled for months. I had told mark 10/31 as well. My apologies. Can we still do 10/31? Sent from my iPhone On Oct 28, 2019, at 5:51 PM, Hi wrote: Per my email on October 24 below, we were confirmed for Monday (which was today, October 28). From: Sent: Monday, October 28, 2019 5:27 PM To: Cc: Subject: Re: Mark Epstein Greetings. We are set for 10/31 at three per your direction. Did I miss an update? Sent from my iPhone On Oct 28, 2019, at 3:12 PM, wrote: EFTA00039663 Hi
Persons Referenced (3)
“...irmed for a meeting at 3:00 p.m. on Monday at See you then. Thanks. Assistant United States Attorney Southern District of New York Tel: EFTA00039664”
United States Attorney“...irmed for a meeting at 3:00 p.m. on Monday at See you then. Thanks. Assistant United States Attorney Southern District of New York Tel: EFTA00039664”
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EFTA DisclosureRelated Documents (6)
Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 1 of
Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 1 of 40 EXHIBIT 16 EFTA00081180 Case 9:08-cv-807m091349pept Z91-15 _EriterM ocp WERocisstifolf/E15 Page 2 of roio-< uoc 16q0,3 e 0 EXHIBIT C Epstein vs. Edwards Undisputed Statement of Facts EFTA00081181 Case 9:08-cv-807ailaVs kigsyffigt 28415-c1p6Arger phri N 7NRocieatgfe)10/§815 Page 3 of IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 50 2009 CA 040800XXXKMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY I EDWARDS, individually, Defendants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on wh
Subject: SDNY News Clips Friday, August 23, 2019
From: Cc: Bee: Subject: SDNY News Clips Friday, August 23, 2019 Date: Fri, 23 Aug 2019 20:41:55 +0000 Attachments: 2019 8-23.pdf SDNY News Clips Friday, August 23, 2019 EFTA00069870 Contents EFTA00069871 EFTA00069872 EFTA00069873 EFTA00069874 EFTA00069875 EFTA00069876 Epstein Suicide Inquiry Grows: Roughly 15 Jail Workers Are Subpoenaed NYT By Azi Paybarah, William K. Rashbaum, and Danielle Ivory 8/22/19 The warden and the head of the federal Bureau of Prisons have been reassigned. Two employees accused of sleeping on the job and falsifying records have been placed on administrative leave. Now, roughly 15 employees at the Metropolitan Correctional Center where Jeffrey Epstein killed himself in his jail cell have been subpoenaed as the criminal investigation into the events around his suicide intensifies, according to a prison official and a person with knowledge of the matter. The subpoenas, issued in recent days by federal prosecutors in Manhattan, are the lat
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant
90A-NY-3151227 Serial 64
90A-NY-3151227 Serial 64 FD-302 (Rev. 5-8-10) •1 of 1. FEDERAL BUREAU OF INVESTIGATION Date of entry 08/28/2019 On August 16, 2019, at the Metropolitan Correctional Center (MCC) III , New York, NY, Special Agent (SA) , SA , TFO , OIG Investigator and MCC Lt. interviewed LEONARDO FERNANDEZ, MCC Inmate #86824-054. After being advised of the identities of the agents and the purpose of the interview, FERNANDEZ provided the following information: On Friday (August 09, 2019), FERNANDEZ was housed in Cell 218 on L-TIER of the Special Housing Unit within MCC. He received a visit from his girlfriend, TYRELYSHANTI CRIAG, that day. He was suspected of receiving contraband at the visit and was placed in the dry room for approximately 25 hours. FERNANDEZ was then moved to K tier Cell 111. FERNANDEZ last day being housed in L Tier was Friday (August 9, 2019) prior to his visit. FERNANDEZ remembers that JEFFREY EPSTEIN would be in legal from approximately 9am to 9pm and he was
Jeffrey Epstein non‑prosecution agreement and alleged high‑level connections revealed in multiple Palm Beach filings
The passage aggregates numerous contemporaneous reports about a secret non‑prosecution agreement that allowed billionaire Jeffrey Epstein to avoid federal charges, mentions specific federal actors (U. Sealed non‑prosecution agreement between Epstein and U.S. Attorney's Office (2007‑2008) prevented fe Agreement granted immunity to co‑conspirators Sarah Kellen, Adriana Ross, Lesley Groff, Nadia Marc
425 FEDERAL SUPPLEMENT, 3d SERIES
306 425 FEDERAL SUPPLEMENT, 3d SERIES t In short, the issue now before the Court has arisen only because Donziger unjustifi- ably has refused to comply with his discov- ery obligations. Had he done so — i.e., had he produced responsive documents as to which there was no colorable claim of priv- ilege, submitted a privilege log as to re- sponsive documents as to which there was such a colorable claim, and submitted any disputes for judicial resolution - there would be no need to examine his ESI. But he has not. And the Court thus must take appropriate action. His arguments to the contrary are meritless. Conclusion For the foregoing reasons, the Court has entered the protocol for imaging and forensic examination of Donziger's elec- tronic devices and media. SO ORDERED. the six months between being served with the document requests and the Court's eventual ruling, on October I8, 2018, that Donziger had waived any applicable privi- lege. Third, Donziger disregards the
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