09/16/2008
Summary
09/16/2008 17:18 P0DHURST.0RSECK NO.269 8001 YODHURST ORSECK, P.A. City National Bank Building, Suite 800 25 West Flagler Street Miami, FL 33130 Please deliver the following page(s) to: lc em, Roy Black, Esq. From: Robert,. Josefsberg, Esq. Number of page(s): (Including cover page) Our Fax Number: File No. Epstein Date: 9/16/08 MESSAGE: If you do not receive all a es please contact us immediately at: - Extension 3241 THIS IS A PRIVILEGED AND CONFIDENTIAL COMMUNICATION. IF YOU ARE NOT AN INTENDED RECIPIENT, YOU SHOULD: (1) REPLY TO SENDER; (2) DESTROY THIS COMMUNICATION ENTIRELY, INCLUDING DELETION OF ALL ASSOCIATED TEXT FILES FROM ALL INDIVIDUAL AND NETWORK STORAGE DEVICES; AND (3) REFRAIN FROM COPYING OR DISSEMINATING THIS COMMUNICATION BY ANY MEANS WHATSOEVER. THANK YOU. EFTA00220707 09/16,2008 17:18 PODHURST,ORSECK N0.269 I2002 Podhurst,::ssi- Z.:CAL & 72 WIr 2.7.R Aaron a; Podburst Robert I. Josebberg Joel D. Eaton Steven. Marks Victor M. Di
Persons Referenced (3)
“...ler Street Miami, FL 33130 Please deliver the following page(s) to: lc em, Roy Black, Esq. From: Robert,. Josefsberg, Esq. Number of page(s): (Including cover page) Our Fax Number: File No. E...”
U.S. Attorney“...Suite 2218 We are in receipt of letters dated September 2, 2008 from Assistant U.S. Attorney A. that were sent to sexual assault victims of Jeffrey Epstein. That letter advises victims that you wil...”
Jeffrey Epstein“...ck, Srebnicic, et al. 201 S. Biscayne Blvd., Suite 1300 Miami, FL 33131 Re: Jeffrey Epstein Dear Ms. and Gentlemen: Robert Orseck (19344978) Walter H. Beckham. Jr. Karen Podhurst Dan Of Omms...”
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EFTA DisclosureRelated Documents (6)
Rol Slack lir „kite'
Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde
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
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
Epstein Depositions
10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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
c -vntit 4t 13/acicari1/4
c -vntit 4t 13/acicari1/4 6olotionf EFTA00192767 (USAFLS) From: ..pi (USAFLS) Sent: ues ay, une , 8 3:08 PM To: Roy BLACK Subject: RE: FW: Jeffrey Epstein Hi Roy -- Is this the best number to call? Assistant U.S. Attorne West Palm Beach, FL 33401 Phone Fax Original Message From: Roy BLACK [mailto: Sent: Tuesda , June 24, 2008 3:02 PM To: . (USAFLS) Cc: jack goldberger Subject: Re: FW: Jeffrey Epstein I that is a good time. I also want to conference Jack Goldberger into the call. This will be a wrap up call. Roy USAFLS)" > 6/24/2008 12:23 PM >>> Dear Roy: contacted me and asked me to return your call regarding the Epstein matter. I am forwarding to you an e-mail that I sent to Jay Lefkowitz last night. and I can call you at 3:30 to speak about your list of issues. If that time does not work, please let me know what times you are available. Thank you. Assistant U.S. Attorne West Palm Beach, FL 33401 Phone Fax From: . (USAFLS) Sent: Monda June
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