To: "Roy BLACK"
Summary
From: To: "Roy BLACK" Cc: Subject: Jeffrey Epstein Date: Wed, 13 Aug 2008 19:28:08 +0000 Importance: Normal Dear Roy — Judge Marra has set us for a status conference tomorrow afternoon in Jane Doe v. United States. Given Judge Marra's past rulings, I anticipate that he may order us to turn over the agreement, so we need to get this issue resolved today, if at all possible. Thank ou, Assistant U.S. Attorne Phone Fax EFTA00067305
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EFTA DisclosureRelated Documents (6)
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70
Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 1 of 70 EXHIBIT A PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS EFTA00208682 Case 9:08-cv-80736-KAM Document 224-1 Entered on FLSD Docket 08/16/2013 Page 2 of 70 PRIVILEGE LOG - WITH VICTIMS' OBJECTIONS Key to Objections (linking to Victims' Motion to Compel Production of Docments that Are Not Prig ileged Objection General Objections -- Inadequate Privilege Log Failure to Prove Factual Underpinnings of Privilege Claim Waiver of Confidentiality Government's Fiduciary Duty to Crime Victims Bars Privilege Communications Facilitating Crime-Fraud-Misconduct Not Covered Factual Materials Not Covered Documents Not Prepared in Anticipation of CVRA Litigation Attorney Client Objections - Ordinary Governmental Communications Not Covered Attorney-Client Relationship Not Established Deliberative Process Objections - Privilege Not Properly Invoked Final Decision Exempted from Privilege Qualified Privilege Ove
Westlaw.
Westlaw. Pagel 749 F.3d 999, 24 Fla. L. Weekly Fed. C 1270 (Cite as: 749 F.3d 999) H United States Court of Appeals, Eleventh Circuit. Jane DOE NO. 1, Jane Doe No. 2, Plaintiffs-Appellees, 1. UNITED STATES of America, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13-12923. April 18, 2014. Background: Alleged minor victims of federal sex crimes brought action against the United States alleging violations of the Crime Victims' Rights Act ( CVRA) re- lated to the United States Attorney Office's execution of non-prosecution agree- ment with alleged perpetrator. After the victims moved for disclosure of corres- pondence concerning the non-prosecution agreement, the alleged perpetrator and his criminal defense attorneys intervened to assert privilege to prevent the disclos- ure of their plea negotiations. The United States District Court for the Southern District of Florida Court, No. 9:08-CV-80736-KAM, ordered disclosure. The inter- v
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res
Memorandum
Memorandum Subject Re: Operation Leap Year Date May 1, 2007 (Revised 9/13/07) (2nd Revision 2/19/08)' To From R. Alexander Acosta, United States Attorney First Assistant United States Attorney Chief, Criminal Division MAUSA, Northern Region , Chief, Northern Region I. Introduction This memorandum seeks approval for the attached indictment char in Jeffrey Epstein, Min a/k/a' JEGE Inc., and Hyperion Air, Inc. The proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes? The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk' and, from information we have received, a continued danger 'The second revision amends the Jane Doe numbering system to correspond with the most recent indictment. It also removes the references to the overt acts and substantive allegations related to each
Alfredo Rodriguez’s stolen “golden nugget” – a bound book linking Jeffrey Epstein to dozens of world leaders and billionaires
The passage describes a former Epstein employee, Alfredo Rodriguez, who allegedly stole a bound book containing the names, addresses and phone numbers of high‑profile individuals (e.g., Henry Kissinge Rodriguez claims the book lists names, addresses and phone numbers of dozens of influential individu He tried to sell the book to an undercover FBI agent for $50,000, indicating awareness of its valu
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23
Case 9:08-cv-80736-KAM Document 161 Entered on FLSD Docket 04/17/2012 Page 1 of 23 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. SUPPLEMENTAL BRIEFING OF INTERVENORS ROY BLACK, MARTIN WEINBERG, AND JAY LEFKOWITZ IN SUPPORT OF THEIR MOTION FOR A PROTECTIVE ORDER CONCERNING PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS During the hearing on August 12, 2011, the Court directed the proposed intervenors to file additional briefing on their argument that plea negotiations are privileged and not subject to discovery or use as evidence in these proceedings. Proposed intervenors submit the following memorandum of law, which is identical to Parts I and II of the memorandum of law submitted by proposed intervenor Jeffrey Epstein in support of his motion for a protective order and his opposition to the motions of the plaintiffs for production, use,
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