EFTA00021651Set 8
2019-07-239p1,444w
Discovery disclosed to the defendant
("Defendant") and/or to the defendant's attorneys ("Defense
Counsel") during the course of proceedings in this action:
a) Shall be used by the defendant ... forth in
paragraph 2(d) below;
d) May be disclosed only by Defense Counsel and
only to the following persons ("Designated Persons"):
i. investigative, secretarial, clerical,
or paralegal personnel employed ... expert, advisor, or any other
individual retained or employed by the Defendant and Defense
Counsel for the purpose of assisting in the defense of this case
("Defense Experts/Advisors");
iii. such
https://www.justice.gov/epstein/files/DataSet%208/EFTA00021651.pdf
EFTA00084069Set 9
2020-07-3012p2,246w
Discovery disclosed to the defendant
("Defendant") and/or to the defendant's criminal defense
attorneys ("Defense Counsel") during the course of proceedings
in this action:
a) Shall be used ... Defendant or her
Defense Counsel solely for purposes of the defense of this
criminal action, and not for any civil proceeding or any purpose
other than the defense of this ... Shall not be copied or otherwise recorded or
transmitted by the Defendant, except to Defense Counsel, or
except as necessary for the Defendant to take notes, which
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084069.pdf
EFTA01201640Set 9
2007-09-248p4,217w
Wexner), through his
counsel, without a substantial investigatory justification.
MV issued subpoenas to Defense counsel's investigators seeking to learn the content of
the investigators' work for counsel without complying ... Subpoenas to Lavery dated June 6, 2007 and
Riley dated June 18, 2007. When Defense counsel questioned this, MV cited irrelevant
authorities to justify her misconduct, though in fact ... respect to such alleged
victims.
5. Before and after the execution of the NPA, Defense counsel repeatedly expressed
concerns to the USAO that by refusing to disclose until after
https://www.justice.gov/epstein/files/DataSet%209/EFTA01201640.pdf
EFTA00206764Set 9
2008-05-3029p8,407w
plea discussions took place between Jeffrey Epstein,
represented by numerous attorneys (including lead criminal defense counsel Jay Lefkowitz), and
the U.S. Attorney's office for the Southern District of Florida ... received copies of half of the e-mail
correspondence (the half reflecting communications to defense counsel) on about June 30,
2010. See Edwards Declaration at & &20-22.
5
EFTA00206768 ... learning what was
happening through the press. She wrote in an e-mail to defense counsel: "On an 'avoid the
press' note, I believe that Mr. Epstein's airplane
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206764.pdf
EFTA00189362Set 9
2008-03-2138p11,670w
victims for depositions who are not included in the state indictment. (Under
Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems ... victims for depositions who are not included in the state indictment. (Under
Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems ... victims for depositions who are not included in the state indictment. (Under
Florida law, defense counsel are allowed to depose witnesses, including victims, prior to trial.) He seems
https://www.justice.gov/epstein/files/DataSet%209/EFTA00189362.pdf
EFTA00100925Set 9
2020-10-237p3,628w
still cannot read all of the documents in the government's prior productions. Defense
counsel have discussed these issues at length with the Government, and despite the
Government's assurances ... complete set of readable
discovery which she could access at the MDC herself, without defense counsel present.
It was not until October 2, 2020 that the Government created a replacement ... materials.
To compound the problem, we were told by the team leader that defense counsel would
not be permitted to pass Ms. Maxwell papers for her to review or sign
https://www.justice.gov/epstein/files/DataSet%209/EFTA00100925.pdf
EFTA00011475Set 8
2006-07-1914p6,638w
state law enforcement
officials. Through repeated communications with the USAO and senior Department officials,
defense counsel fought the government's interpretation of the NPA's terms. They also sought ... USAO, on
June 23, 2008, the Office of the Deputy Attorney General informed defense counsel that the
Deputy Attorney General would not intervene in the matter. Only then did Epstein ... significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often referred to the interactions among the
participants and described important decisions
https://www.justice.gov/epstein/files/DataSet%208/EFTA00011475.pdf
EFTA00095558Set 9
2006-07-1914p6,638w
state law enforcement
officials. Through repeated communications with the USAO and senior Department officials,
defense counsel fought the government's interpretation of the NPA's terms. They also sought ... USAO, on
June 23, 2008, the Office of the Deputy Attorney General informed defense counsel that the
Deputy Attorney General would not intervene in the matter. Only then did Epstein ... significantly
by extensive, contemporaneous emails among the prosecutors and communications between the
government and defense counsel. These records often referred to the interactions among the
participants and described important decisions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00095558.pdf
EFTA00722736Set 9
2009-04-1737p8,914w
where the deposition of a particular individual may be
applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
Plaintiff's counsel that that ... where the deposition of a particular individual may be
applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
Plaintiff's counsel that that ... where the deposition of a particular individual may be
applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
Plaintiff's counsel that that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722736.pdf
EFTA00731105Set 9
2009-06-168p3,206w
than January 4, 2008." See NPA, ¶ 11.
• On November 28, 2007, Mr. Epstein's defense counsel contacted Assistant Attorney
General Alice Fisher to request a review of certain provisions ... evidence of Mr. Epstein's effort
to breach the NPA.
Second, you state that defense counsel "obstructed [your] ability to abide by [your]
obligations to notify the victims ... Letter from Lefkowitz to Acosta.
Then, on November 28, 2007, you sent defense counsel a proposed victim notification
letter indicating that the alleged victims had a federal right
https://www.justice.gov/epstein/files/DataSet%209/EFTA00731105.pdf
EFTA00080663Set 9
2021-09-2913p5,463w
further provides that any Highly Confidential materials "Shall be made
available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or
employees." Given those provisions ... critical problems with the discovery provided to date.
Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client ... hard-drives with the associated
metadata.
I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review
last week, subject
https://www.justice.gov/epstein/files/DataSet%209/EFTA00080663.pdf
EFTA00040799Set 9
2021-08-2210p4,492w
further provides that any Highly Confidential materials "Shall be made
available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or
employees." Given those provisions ... critical problems with the discovery provided to date.
Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client ... hard-drives with the associated
metadata.
I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review
last week, subject
https://www.justice.gov/epstein/files/DataSet%209/EFTA00040799.pdf
EFTA00094594Set 9
2021-09-2712p5,148w
further provides that any Highly Confidential materials "Shall be made
available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or
employees." Given those provisions ... critical problems with the discovery provided to date.
Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client ... hard-drives with the associated
metadata.
I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review
last week, subject
https://www.justice.gov/epstein/files/DataSet%209/EFTA00094594.pdf
EFTA00065510Set 9
2021-08-0912p4,706w
further provides that any Highly Confidential materials "Shall be made
available for inspection by Defense Counsel and the Defendant, under protection of law enforcement officers or
employees." Given those provisions ... critical problems with the discovery provided to date.
Unfortunately, both in the production to defense counsel and on the hard-drive supplied by your office to our client ... hard-drives with the associated
metadata.
I am requesting that you produce to defense counsel replicas of the two hard-drives that you made available for review
last week, subject
https://www.justice.gov/epstein/files/DataSet%209/EFTA00065510.pdf
EFTA01659896Set 10
2007-11-306p2,589w
AUSAs and as well as a member of the
Federal Bureau of Investigation, presented defense counsel's view of the case, and promised a
willingness to assist in the investigation ... Epstein's unwillingness to spend time in prison, and
various suggestions were raised by defense counsel, including the proposal that Mr. Epstein could
serve a sentence of home confinement
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01659896.pdf
EFTA00205560Set 9
2011-08-1223p7,201w
letters and emails exchanged between the government and defense counsel during plea
negotiations are classic settlement discussions, written with the intention that they remain
confidential. As such, they are protected ... ineffective assistance of counsel. Rompilla v. Beard, 545 U.S. 374 (2005). "The notion
that defense counsel must obtain information that the state has and will use against the defendant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00205560.pdf