EFTA00084567Set 9
2020-07-2819p5,808w
Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense
counsel have conferred regarding a protective order several times via telephone and email between
July 9, 2020, and today ... including as recently as this morning. The Government and defense
counsel have come to an agreement on much of the proposed protective order. However, the
parties disagree ... defendant insists
that the protective order be modified such that she and her counsel would be permitted to "publicly
referenc[e]" individuals, by name, who have "spoken on the public
https://www.justice.gov/epstein/files/DataSet%209/EFTA00084567.pdf
EFTA00027268Set 8
2020-11-2322p6,962w
Over the past three months, the
Government has had multiple conversations with MDC legal counsel regarding the defendant's
conditions of confinement. This update is based on information provided ... defendant is alone and where
no MDC staff can hear her communications with counsel.
On November 18, 2020, the Government provided the MDC with a laptop for the defendant ... over the past three months, the Government has repeatedly communicated
both with MDC legal counsel and defense counsel regarding the defendant's conditions of
confinement. Whenever the defense has raised
https://www.justice.gov/epstein/files/DataSet%208/EFTA00027268.pdf
EFTA00801674Set 9
2005-09-287p1,997w
Jeffrey Epstein (the "Client"), and the law firm of
Black, Srebnick, Kornepan & Stumpf, P.A. ("Counsel " or the 'Firm 1, 201 S.
Biscayne Boulevard, Suite 1300, Miami, Florida 33131.
1. SCOPE ... ENGAGEMENT
A. Matter Involved. The Client has engaged Counsel to undertake the
legal representation of the Client in the following matter (the °Mattes"):
Palm Beach County investigation. The Client acknowledges ... flat fee basis, which will need to be agreed upon prior to Counsel's
entrance of a permanent notice of appearance.
B. graraLfuncitiQug. By the terms of this Agreement, Counsel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801674.pdf
EFTA01200390Set 9
2015-07-0651p13,320w
Petitioners moved "to allow use of correspondence between the U.S.
Attorney's Office and counsel for Epstein" to prove their CVRA case. (DE 51 at I). Petitioners
argued that ... certain degree of privacy, free from unnecessary intrusion by
opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The
privilege is codified at Federal Rule ... Department of Justice's Office of Professional Responsibility (OPR) in
response to Petitioners' counsel's request for an investigation into the Government's handling of
the Epstein case
https://www.justice.gov/epstein/files/DataSet%209/EFTA01200390.pdf
EFTA00622924Set 9
2010-06-0461p16,815w
motion (3/9/10 Order attached as Exhibit A).
7. On April 5, 2010, counsel for Epstein wrote to counsel for Rothstein to
coordinate Rothstein's deposition and indicated that since Rothstein ... deposition would likely have to be moved. ask 4/5/10 Letter attached as
Exhibit B. Counsel for Rothstein never responded to said letter.
8. On April 15, 2010, Epstein filed ... depose Rothstein (4/22/10
Order attached as Exhibit C).
10. However, Rothstein's own counsel has had considerable difficulty locating
and communicating with his client. In an April 22, 2010 article
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622924.pdf
EFTA01074153Set 9
2011-06-0211p2,554w
Michael Szafranski (D.E. 1725).
Upon consideration of the record, and the arguments of counsel at the hearings of April
25 and May 18,2011, it is hereby ORDERED as follows ... form similar to the proposed Writ attached as Exhibit "A" to this Order. Counsel for the Trustee,
Gibraltar and the Razorback creditors are directed to present to the Clerk ... represented by additional retained professionals. The
Creditors' Committee may be represented by its lead counsel, in addition to counsel for the
4
EFTA01074156
Case 09-34791-RBR Doc 1751 Filed
https://www.justice.gov/epstein/files/DataSet%209/EFTA01074153.pdf
EFTA00316512Set 9
25p15,696w
like other presidents, he is not like anyone the Office of the Special Counsel.
most of us have ever known. Hence, everyone who has been close to him Dealing with ... Make it go away, make
go away, make it go away"
The White House counsel Don McGahn—representing the Whi
EFTA00316516
2 MICHAEL WOLFF
SIEGE
House rather than ... near future he wot
EFTA00316517
4 MICHAEL WOLFF SIEGE
hear directly from the special counsel, who would send him a compre- after the FBI had first raised questions about National
https://www.justice.gov/epstein/files/DataSet%209/EFTA00316512.pdf
EFTA01180323Set 9
2014-04-2446p10,094w
banc can be timely filed and decided by this Court.
The government has informed counsel that, absent the continuation of the stay,
it will turn over the documents to plaintiffs ... counsel by Friday, May 2, 2014, making
this motion time senstive. Accordingly, pursuant to 11th Cir. R. 27-1(b), the
Intervenors request a ruling on this motion from ... Intervenors have contacted both the
Clerk's Office of this Court and opposing counsel telephonically and advised them of
this time sensitive Motion.
In support of this time sensitive motion
https://www.justice.gov/epstein/files/DataSet%209/EFTA01180323.pdf
EFTA00164836Set 9
2019-07-255p958w
disseminated to or
provided copies of to, prospective witnesses and their counsel
(collectively, "Potential Witnesses"), to the extent deemed
necessary by defense counsel, for trial preparation.
2. To the extent ... disclosed to
Defense Staff, Defense Experts/Advisors, Other Authorized
Persons, or Potential Witnesses, Defense Counsel shall instruct
such individual(s) of the terms of this Order and that such
individual ... that
Discovery is disseminated to Defense staff, Defense
Experts/Advisors, or Other Authorized Persons, Defense Counsel
shall encrypt and/or password protect the Discovery. The
provisions of this paragraph do not apply
https://www.justice.gov/epstein/files/DataSet%209/EFTA00164836.pdf
EFTA01128826Set 9
2012-11-304p1,225w
individually,
Defendant(s).
NOTICE OF ADDITIONAL AUTHORITY
COMES NOW Fred Haddad, as co-counsel for Epstein, files this Notice to the Court of
recent additional authority that the undersigned would ... CERTIFY that a copy of the foregoing was furnished via Email to a►l counsel
listed below, this th" day of December, 2012.
FRED HADDAD, P.A.
One Financial Plaza, Suip ... Fort Lauderdale, Florida3394
Tel:
Fax:
Page 1 of 2
EFTA01128826
COUNSEL LIST
Jack Scarola, Esq.
E-mail:
2139 Palm Beach Lakes Blvd
West Palm Beach. Florida 33409
Jack Goldberger
https://www.justice.gov/epstein/files/DataSet%209/EFTA01128826.pdf
EFTA00184197Set 9
2008-07-1527p7,073w
contact with C.W. and S.R. Attorney Edwards' other client,
T.M., was represented by counsel and, accordingly, all contact with T.M. was made through
that attorney. That attorney was James Eisenberg ... ofthe agreement, but before Epstein
performedhis obligations, C.W. contacted the FBI because Epstein's counsel was attempting
to take her deposition and private investigators were harassingher. Your Affiant secured ... bono counsel to represent C.W. and several other identified victims. Pro bono counsel was
able to assist C.W. in avoiding the improper deposition. That pro bono counsel did not
express
https://www.justice.gov/epstein/files/DataSet%209/EFTA00184197.pdf
EFTA00206619Set 9
2010-09-025p1,100w
Lehrman, PL. (the "Law 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").
2. Counsel for Jane Doe and Counsel for Epstein disagree whether the
Correspondence is confidential.
3. Without in any way altering the obligations set forth ... CA028051 JODOCMB AB and E.W. vs. Epstein, CASE NO. 502008 CA028058
XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v,
Rothstein, CASE NO. 502009CA040800/OOOCMB
https://www.justice.gov/epstein/files/DataSet%209/EFTA00206619.pdf
EFTA00213912Set 9
2010-09-025p1,166w
Lehrman, PL. (the "Law 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").
2. Counsel for Jane Doe and Counsel for Epstein disagree whether the
Correspondence is confidential.
3. Without in any way altering the obligations set forth ... CA028051 JODOCMB AB and E.W. vs. Epstein, CASE NO. 502008 CA028058
XXXXMB AB, Counsel may wish to use the Correspondence in pending cases of Epstein v,
Rothstein, CASE NO. 502009CA040800/OOOCMB
https://www.justice.gov/epstein/files/DataSet%209/EFTA00213912.pdf
EFTA00216141Set 9
2008-11-256p3,151w
November 25, 2008
VIA ELECTRONIC MAIL AND U.S. MAIL
Ms. Heidi E. Brewer
Bar Counsel
Attorney Consumer Assistance Program
The Florida Bar
Re: Stuart Samuel Mermelstei
Dear Ms. Brewer:
Thank ... handled. On September 18, 2008, I sent, via electronic mail, a
letter to Ethics Counsel for the Florida Bar seeking guidance on this matter because there were
several victims whom ... have enclosed herewith that correspondence,
including the attachments and the response of Assistant Ethics Counsel Gail E. Ferguson, dated
November 4, 2008.
In her letter, Ms. Ferguson reported that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00216141.pdf
EFTA00804562Set 9
2018-03-139p1,562w
surrounding the apparent theft of these
confidential materials, Judge Hafele directed Epstein's current counsel to simply file
all the materials with him under seal, thereby permitting him to control ... things could be sorted out. Exhibit A at pp. 74, 89. Epstein's current counsel
stipulated to the order. Id. at 74.
This Court's Stay Is Interfering with Implementing ... Thursday, March 8.
Before a confirming written order could be agreed among all counsel, this Court
entered a stay of "all proceedings" below on the afternoon of Friday, March
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804562.pdf
EFTA01085801Set 9
2014-02-0639p15,763w
HEREBY CERTIFY that a true copy of the foregoing was furnished to all
counsel on the attached service list, by email, on December 30, 2014.
SEARCY DENNY SCAROLA
BARNHART & SHIPLEY ... lawsuit somehow becomes protected activity,
then Florida will stand alone among all the states.
Counsel have undertaken a broad survey of the laws and court decisions in fifty states ... District of Columbia. At this point, counsel have been unable to locate even a single
precedent from another state that would support such an extreme result. On the other hand
https://www.justice.gov/epstein/files/DataSet%209/EFTA01085801.pdf