EFTA01103326Set 9
39p29,306w
your date of birth? 12 question, and we may or may not invoke Fifth
13 A. January 20th, 1953. 13 Amendment privileges and there may be times ... particular question, but on
17 Beach? 17 those questions that we do invoke Fifth
18 A. I intend to respond to all relevant 18 Amendment privileges, I think we have ... representation. 24 questions regarding this lawsuit. However, in the
25 Accordingly, I assert my Fifth, Federal 25 present my attorneys have counseled me that I cannot
Page 6 Page
https://www.justice.gov/epstein/files/DataSet%209/EFTA01103326.pdf
EFTA01723963Set 10
100p18,558w
hours of harassing
17 questions to that she sometimes
18 invoked her Fifth Amendment rights, I
19 understand the adverse advice that would be
20 given and she was made ... lawsuit, so accordingly I assert
18 my constitutional rights as guaranteed by the
19 Fifth, Sixth and Fourteenth Amendment.
20 Q Are you invoking your Fifth Amendment
21 rights ... going to instruct him not to answer that
8 question, based upon his Fifth, Sixth and
9 Fourteenth Amendment rights to the United
10 States Constitution.
11 MR. With
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01723963.pdf
EFTA01076650Set 9
2010-03-0848p38,457w
advice of counsel, I am going
6 MR. PIKE: Foam 6 to assert my Fifth Amendment Right.
7 THE WITNESS: I registered on — in, I believe, 7 BY MR. HOROWITZ ... advice of counsel, I'm going 18 A No.
19 to assert my Fifth Amendment Right as to that. 19 Q Okay. In June of 2008, you pled guilty ... counsel, fm going 7 prostitution, was a female, correct?
8 to assert my Fifth Amendment Right 8 A On advice of cowisel, I am going to have
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076650.pdf
EFTA00589713Set 9
2017-03-0910p2,848w
justice for Mr. Epstein to be compelled to appear personally to assert his Fifth
Amendment privilege. Indeed, the weakness of plaintiffs arguments provides additional
compelling reason why Mr. Epstein ... cannot
justify requiring Mr. Epstein to appear personally to repeat the assertions of his Fifth
Amendment privilege that he made during his videotaped deposition, it bears noting that the
recent ... full
understanding of the principled basis for Mr. Epstein's assertion of his Fifth Amendment
privilege. Tr. 3/9/17 at 39-40. Thus, his arguments that he wishes to call
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589713.pdf
EFTA01141657Set 9
2013-09-1626p4,949w
means
7 that while we have acknowledged that
8 Mr. Epstein has a valid Fifth Amendment
9 privilege because he does clearly remain in
10 jeopardy with regard ... clearly permitted to
20 draw an adverse inference from the assertion
21 of the Fifth Amendment, the right to remain
22 silent.
23 So we need to eliminate the invalid ... those circumstances where the only privilege
10 asserted by Mr. Epstein is a Fifth Amendment
11 privilege, his right to remain silent pursuant
12 to the Fifth, Sixth and Fourteenth
https://www.justice.gov/epstein/files/DataSet%209/EFTA01141657.pdf
EFTA00222502Set 9
2009-03-0216p3,973w
Defendant has produced no information and no documents. Defendant's principal objection
concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set
forth a sufficient predicate ... information. Defendant, rather, repeats in each response an
all-encompassing, blanket assertion of Fifth Amendment privilege.
Defendant's responses also include a laundry list of objections to Plaintiff's interrogatories ... Amendment right to effective representation.
Accordingly, I assert my federal constitutional rights under the Fifth,
Sixth, and Fourteenth Amendments as guaranteed by the United
States Constitution.
Defendant's canned objection
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222502.pdf
EFTA00210758Set 9
2015-01-2980p24,607w
Crime.
The CVRA gives victims rights during the investigation of a crime. The Fifth Circuit
recently reached this conclusion, holding:
The district court acknowledged that Itihere are clearly rights
under ... have this conference with prosecutors before any final plea
agreement is reached. The Fifth Circuit reached exactly this conclusion in a very recent case. In
In re Dean, 527 F.3d ... without conferring with the victims. When the Government's
failure was challenged in the Fifth Circuit, the Fifth Circuit concluded that the Government had
indeed violated the CVRA. The Fifth
https://www.justice.gov/epstein/files/DataSet%209/EFTA00210758.pdf
EFTA00582821Set 9
2017-06-3024p7,457w
strike this affidavit, and asserts as
grounds therefor Epstein's assertion of his Fifth Amendment Privilege against self-incrimination
in response to discovery posed to Epstein. However, as demonstrated below ... assert the following privileges to certain questions posed by Edwards: attorney-client
and Fifth Amendment. However, Epstein answered all of the questions actually germane to this
lawsuit Even a cursory ... review of Epstein's deposition unequivocally shows that he only asserted
his Fifth Amendment Privilege when asked questions of a criminal nature; questions which have
no bearing on his abuse
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582821.pdf
EFTA00613940Set 9
2009-03-0358p16,044w
January 1, 2005
will indefinitely remain subject to its current lock-up." Id.2
The Fifth Investment and Subscription Agreement
In late 2004, Mr. Epstein apparently wished to make yet another ... rolling lock-up. The Fund agreed.
Thus, on January 1, 2005, Jeepers executed a fifth subscription agreement
for an additional $20 million limited partnership interest in Fund (the "Fifth Investment ... January 11, 2005, in connection with Jeepers's Fifth Investment, the General Partner
agreed in a side letter (the "Side Letter"), which refers specifically to Jeepers's "January
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613940.pdf
EFTA00208374Set 9
2011-03-2142p12,054w
investigation of federal criminal cases.
In a case remarkably similar to this one, the Fifth Circuit has held that victims have a
right to confer with federal prosecutors even before ... conferring with the victims. When challenged on a mandamus petition by the
victims, the Fifth Circuit held:
The district court acknowledged that "[tJhere are clearly rights
under the CVRA that ... attempt to distinguish Dean, it asks this Court to
decline to follow the Fifth Circuit's holding and create a split of authority on this important
issue
https://www.justice.gov/epstein/files/DataSet%209/EFTA00208374.pdf
EFTA00076712Set 9
2019-07-06102p25,844w
seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number ... lower left shelf of a white
wooden cabinet in a room on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ... which was seized from on top of a desk in a mom on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076712.pdf
EFTA00091454Set 9
2019-07-06102p25,839w
seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number ... lower left shelf of a white
wooden cabinet in a room on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ... which was seized from on top of a desk in a mom on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number
https://www.justice.gov/epstein/files/DataSet%209/EFTA00091454.pdf
EFTA02453754Set 11
2018-05-0210p1,333w
that access set up for the union employees
DAVID MITCHELL
Mitchell Holdings LLC
745 Fifth Avenue
New York NY 10151
USA
On May 2, 2018, at 6:04 AM, jeffrey ... David Mitchell
wrote:
Update
DAVID MITCHELL
<https://maps.google.comfici=745+Fifth+Avenue++%0D%0A+New+York+NY+10151+`/G0DMA+USA&entry=gmai
l&source=g>
<https://maps.google.com/?q=745+Fifth+Avenue++°/00D ... entry=gmai
l&source=g>
Mitchell Holdings LLC
745 Fifth Avenue
<https://maps.google.com/?q=745+Fifth+Avenue++%0D%0A+New+York+NY+10151+%0D%0A+USA&entry=gmail&sourc
e=g>
New York NY 10151
<https://maps.google.com/?q=745+Fifth+Avenue++%0D%0A+New+York+NY+10151+%0D%0A+USA&entry=gmail&sourc
erg>
EFTA_R1_01554874
EFTA02453754
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02453754.pdf
EFTA00153059Set 9
2019-07-06102p25,840w
seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number ... lower left shelf of a white
wooden cabinet in a room on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ... which was seized from on top of a desk in a mom on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number
https://www.justice.gov/epstein/files/DataSet%209/EFTA00153059.pdf
EFTA00722655Set 9
2009-04-0933p7,965w
motion to stay these proceedings, defendant Epstein has argued that he
must invoke his Fifth Amendment rights lest he be found in violation of a non-
prosecution agreement with ... refusing to grant a stay a
civil proceeding before any indictment was returned because Fifth Amendment
concerns, if any, were weak).
Not only has Epstein failed to show the existence ... Defendant does not breach the agreement, then
he should have no concerns regarding his Fifth Amendment right against self-
incrimination." Order Denying Motion to Stay at 4, Jane
https://www.justice.gov/epstein/files/DataSet%209/EFTA00722655.pdf
EFTA00222985Set 9
2007-07-107p2,927w
subpoenas to Riley and Riley Kiraly; second, that the subpoenas violate Epstein's Fourth, Fifth, and Sixth
Amendment rights; third, that the subpoenas are unreasonable because they seek items "unconnected ... investigation," fourth, that the subpoenas are unreasonable because they are "oppressive, overbroad,
and unparticularized;" fifth, the subpoenaed items contain information and documents protected by the attorney-
client and work product ... privileges; and sixth, that the subpoena of "purely private papers violates the Fifth
Amendment under ."
In response, the United States first does not object to the motion to intervene
https://www.justice.gov/epstein/files/DataSet%209/EFTA00222985.pdf