Frain: "Weinstein. Marc A."
Summary
Frain: "Weinstein. Marc A." 'In: Cc: "Tomback, Andrew" candrew.tomback@whitecase.com> Subject: Grand jury subpoena response Date: Fri, 24 Jan 2020 20:46:20 +0000 Attachments: 1-24-2020_Production_Set_l_-_Trust_One_Doct(Bates_GL000198-GL000253).zip; 1- 24-2020_Production_Set_2_-_Trust_Two_DocsiBates_GL000254-al_000332).zip In response to your request for any prior trusts referenced in the prior wills of Jeffrey Epstein produced on January 16, 2020, which further request we understand is made pursuant to the October 18, 2019 grand jury subpoenas to the executors of the estate of Jeffrey Epstein, attached please find documents bearing Bates numbers G.1_000198 through GJ_000332. Although the second zip file attached (Production Set 2) contains documents not specifically identified in your January 16, 2020 email, we are providing them for completeness. I will be sending additional documents in separate emails. Regards, Marc Marc A. Weinstein I Partner Chair, White Collar Defe
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reached in this case, and other information in the possession of the victims, it is also possible that
reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science
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Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33
Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 1 of 33 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE 1 AND JANE DOE 2, Petitioners, vs. UNITED STATES, Respondent. OPINION AND ORDER This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Motion for Partial Summary Judgment (DE 361); the United States's Cross-Motion for Summary Judgment (DE 408); Jane Doe 1 and Jane Doe 2's Motion to Compel Answers (DE 348) and Jane Doe 1 and Jane Doe 2's Motion for Finding Waiver of Work Product and Similar Protections by Government and for Production of Documents (DE 414). The Motions are fully briefed and ripe for review. The Court has carefully considered the Motions and is otherwise fully advised in the premises. I. Background The facts, as culled from affidavits, exhibits, depositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From betw
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