EFTA01072194Set 9
2013-06-1858p13,073w
including intervenors/appellants Roy Black and Martin
Weinberg, authored, and sent to government prosecutors, the correspondence
which is the subject of this appeal, fully expecting, based on Fed. R. Crim ... Epstein, No. 08-80119-MARRA, Doc.
462. In response to that order, settlement negotiation correspondence authored by
government prosecutors (not by Epstein's counsel) was produced to plaintiffs.
Once ... their civil monetary remedies against Mr. Epstein to completion —
plaintiffs sought to use that correspondence in their CVRA case in support of their
contentions that the government had violated their
https://www.justice.gov/epstein/files/DataSet%209/EFTA01072194.pdf
EFTA01197325Set 9
2014-04-1824p5,755w
under the Crime Victims'
Rights Act, 18 U.S.C. § 3771, and sought to discover the correspondence between
Epstein's attorneys and the United States regarding the non-prosecution agreement.
Epstein ... district court overruled their objection and ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss ... documents given to Epstein's attorneys during his plea negotiations.
The victims received correspondence written by the United States, but they never
received any correspondence written by Epstein's attorneys
https://www.justice.gov/epstein/files/DataSet%209/EFTA01197325.pdf
EFTA00209741Set 9
2014-04-1823p5,318w
under the Crime Victims'
Rights Act, 18 U.S.C. § 3771, and sought to discover the correspondence between
Epstein's attorneys and the United States regarding the non-prosecution agreement.
Epstein ... district court overruled their objection and ordered the United States to
disclose the correspondence to the victims. After the intervenors filed this appeal,
the victims moved to dismiss ... documents given to Epstein's attorneys during his plea negotiations.
The victims received correspondence written by the United States, but they never
received any correspondence written by Epstein's attorneys
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209741.pdf
EFTA00209534Set 9
2013-07-1225p5,708w
Disinterested Third Party 15
III. INTERVENORS WILL SUFFER INJURY IF THE
PRIVILEGED AND CONFIDENTIAL CORRESPONDENCE
IS DISCLOSED TO PLAINTIFFS 17
CONCLUSION 20
EFTA00209535
Case: 13-12923 Date Filed: 07/12/2013 Page ... civil litigation, "Epstein's counsel produced to the victims' counsel
significant parts of the correspondence by his attorneys concerning the NPA," Motion
at 6, is misleading, as only correspondence from ... government to Mr. Epstein's
attorneys was produced to plaintiffs, not correspondence authored by Mr. Epstein's
counsel during the course of the negotiations. See United States' Response to
Supplemental
https://www.justice.gov/epstein/files/DataSet%209/EFTA00209534.pdf
EFTA00206520Set 9
2010-07-206p1,401w
Stipulation provides that Counsel for Jane Doe and Counsel
for Epstein disagree whether certain correspondence, defined by the parties as
"correspondence and documents (including content thereof) between Epstein's
attorneys/agents ... Rothstein case"
wished to file, disclose or make available to anyone else the subject Correspondence, said
Counsel or Mr. Edwards must first provide Epstein's Counsel with seven (7) days ... August 26, 2010, Plaintiffs' Counsel served Notice of its intent to use the
Correspondence in two separate court proceedings, an internal Justice Department
Complaint procedure (and in connection with this
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206520.pdf
EFTA00213912Set 9
2010-09-025p1,166w
JANE DOE and Defendant, JEFFREY EPSTEIN ("Epstein"), hereby file their
Joint Stipulation Regarding Certain Correspondence Obtained By Jane Doe's attorneys during
discovery, and each state:
I. In July ... Finn"), Paul G. Cassell, Esq. and Jay Howell, Esq. ("Counsel")
received through discovery certain correspondence and documents (including content thereof)
between Epstein's attomeys/agents and federal prosecutors (the "Correspondence ... Counsel for Jane Doe and Counsel for Epstein disagree whether the
Correspondence is confidential.
3. Without in any way altering the obligations set forth in the Addenda to Settlement
Agreements
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213912.pdf
EFTA00587856Set 9
2014-06-1114p3,437w
mind-brain correlates.
Write the letter of the concept on the line preceding the corresponding paragraph. Use each
letter once.
A. Verificationism
B. Falsificationism
C. Existence Proof
D. Neuroanatomically-Dissociable ... other animals. Write the letter of the method on the line preceding
the corresponding description. Use each letter once.
A. MRI (a.k.a., anatomical MRI)
B. PET
C. MEG
D. fMRI ... Write the
letter of the type of sound-picture on the line preceding the corresponding description.
A. Acoustic Waveform
B. Amplitude Spectrum (a.k.a., Power Spectrum, Magnitude Spectrum)
C. Spectrogram (a.k.a
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587856.pdf
EFTA00206003Set 9
2011-11-22163p26,539w
Answers to all of the victims' requests for admission;
(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of
the federal Government ... received from persons or entities outside of the federal government; and
(4) All documents, correspondence, and other information covered by the victims' discovery request that is not subject ... Answers to all of the victims' requests for admission;
(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of
the federal Government
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206003.pdf
EFTA00299850Set 9
2008-10-019p1,509w
FILE CABINET ONE
DRAWER ONE:
The Florida Science Foundation. Inc.
I. Correspondence
2. Articles of Incorporation
3. Office Space
4. Lease Agreement
5. Annual Report
6. Mark Dedick- Draft Corporate ... Disputed Mark Dedick Invoices
COUQ Foundation, Inc. Organizational ( d/b/a Florida Science Foundation
1. Correspondence
2. Attorney Notes
3. Research
4. Memorandum
5. Certificate of Incorporation
6. By-Laws
7. Minutes ... Expenses
32. FSF Invoices from Comiter, Singer, Baseman and Braun
33. FSF Correspondence
34. FSF Office Lease Second Amendment (April 1, 09- July 31, 09)
35. Grant Agreement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00299850.pdf