MARTIN G. WEINBERG, P.C.
MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW 20 PARK PLAZA, SUITE BM BOSTON. MASSACHUSETTS 02116 (617)n7-37.2 FAX (6 7) J.IS-95.11 NIGHT EMERGENCY: (6l7)901,1472 Sou thern District of Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear July 22, 2011 EMAIL ADDRESSES: owlmetiRmtnel owImps€,MLnei Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
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MARTIN G. WEINBERG, P.C. ATTORNEY AT LAW 20 PARK PLAZA, SUITE BM BOSTON. MASSACHUSETTS 02116 (617)n7-37.2 FAX (6 7) J.IS-95.11 NIGHT EMERGENCY: (6l7)901,1472 Sou thern District of Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear July 22, 2011 EMAIL ADDRESSES: owlmetiRmtnel owImps€,MLnei Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York. We thank you for providing notice of the intended disclosure but we do object to any disclosure of the Non-Prosecution Agreement and the related list of witness/victims on the basis of the confidentiality provisions of paragraph 13. Absent an enforceable subpoena - which we would have the right to move to quash in the Court from which it was issued - there exists no right or duty to disclose the confidential Non-Prosecution Agreement or the non-public witness/victim list which was referenced in paragraph 7 of the
Persons Referenced (2)
“...y Epstein Dear July 22, 2011 EMAIL ADDRESSES: owlmetiRmtnel owImps€,MLnei Roy Black forwarded to me your letter to him dated July 21, 2011, from the District Attorney of the County of New York....”
Jeffrey Epstein“...Florida 500 S. Australian Ave. Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear July 22, 2011 EMAIL ADDRESSES: owlmetiRmtnel owImps€,MLnei Roy Black forwarded to me your let...”
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From: Jeffrey Epstein <[email protected]>
UNITED STATES DISTRICT COURT
EFTA01682184
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, [REDACTED - Survivor], 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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL UNDER SEAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNDER SEAL UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS-MOTION TO COMPEL The United States, by and through the undersigned Assistant United States Attorney, hereby files this Motion for Permission to File an Oversized Response, and, in support thereof, states: 1. Movant Jeffrey Epstein, by and through counsel, filed a Motion to Intervene and to Quash two grand jury subpoenas duces tecum on July
From: Richard Kahn
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