Epstein Secrets

erns." See Exhibit 6, December 19, 2007 Letter from U.S. Attorney Acosta to Attorney Lilly Ann Sanchez at 3. He also stated that he had spoken with AAG Fisher to ask that she review this matter and to expedite the process. Id. • In the beginning of January, 2008, Mr. Acosta and I discussed the need for fu

im for damages. whether pursuant to state. federal or common law". Exhibit 2, NPA 1 8. More is required of a plaintiff than to simply allege, as did Jane Doc 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the e

Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had

were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 25. Epstein's conduct caused severe emotional distress to Janc Doe. Epstein knew or had reason to know that his intentional and outrageous conduct would cause emotional distress and damage to Jane Doe, or Epstein a

Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLI

Palm Beach (head of the West Palm Beach branch office), after serving as the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007 Mr. would leave command were Criminal Division Chief, First Assistant USA the SDFL to become AG Fi her's Chief of Staffs Above M

ed female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. i • (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On, o

er 30, 2004, DefendantMIMS placed a telephone call to a telephone used by Jane Doe #3. (23) Ilkor around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe '4, #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. (24) In or around

erns." See Exhibit 6, December 19, 2007 Letter from U.S. Attorney Acosta to Attorney Lilly Ann Sanchez at 3. He also stated that he had spoken with AAG Fisher to ask that she review this matter and to expedite the process. Id. • In the beginning of January, 2008, Mr. Acosta and I discussed the need for f

im for damages, whether pursuant to state. federal, or common law". Exhibit 2, NPA 18. More is required of a plaintiff than to simply allege, as did Jane Doe 101, that she "exclusively seeks civil remedies pursuant to 18 USC 2255." Exhibit 27, Amended Complaint 1 24. Such an averment satisfies only the exc

s, while Jane Doe I1 already bad a pending state court suit filed in July of 2008 seeking damages against Epstein for sexual assault and conspiracy. Jane Doe H in her federal complaint alleged Epstein could "not contest liability for claims brought exclusively pursuant to 18 U.S.C. §2255". Exhibit 27, Amend

ons under the terms of the NPA. I then worked to find pro bono counsel for those victims (Exhibit B-23). On May 15, 2008, CEOS, DAAG Mandelker, and AAG Fisher completed their review, finding that our case against Epstein was neither improper nor inappropriate (Exhibit B-24). By that time, a revised indict

of a federal case, but I don't recall discussing that at the time. 35 I had never before used a non-prosecution 34 As I noted in my filings in the Jane Doe' United States litigation, I had concerns about informing the victims that part of the negotiations involved securing for them the right to obtain d

issues raised are important and must be fully vetted irrespective of timeliness concerns." He also indicated in that letter that he reached out to AAG Fisher to ask that she review this matter and to expedite the process. See December 19, 2007 Letter from Acosta to Sanchez. EFTA00731106 Ms. A. Marie V

ommon law claims SEE NPA of the right to bring contested litigation in the future was not a:made:plead correctly or sufficiently . With respect to Jane Doe Number 101, there was no such waiver. And while Mr. Epstein's counsel still believe the motion to be well-grounded, PLEASE INSERT OTHER DETAILS OF W

ess concerns." See December 19, 2007 Letter from U.S. Attorney Acosta to Attorney Lilly Ann Sanchez at pg 3. He also stated that he had spoken with AAG Fisher to ask that she review this matter and to expedite the process. Id. • In the beginning of January, 2008, Mr. Acosta and I discussed the need for f

of any other claims, federal, state, or common law mandates an additional affirmative act by the plaintiff. No such waiver was filed or even pled. Jane Doe 101 did no more than restate that her complaint in civil action no 9:09-cv-80591-KAM was only for 2255 damages. She never affirmatively waived all

oncerns." See Exhibit 6, December 19, 2007 Letter from U.S. Attorney Acosta to Attorney Lilly Sanchez at 3. He also stated that he had spoken with AAG Fisher to ask that she review this matter and to expedite the process. Id. • In the beginning of January, 2008, Mr. Acosta and I discussed the need for f

7th Floor Ft. Lauderdale, FL 33394 Re: B.B. I. JEFFREY EPSTEIN OUR FILE NO.: 080303 Dear Ms. As you are aware, this firm represents Plaintiff, Jane Doe, a/k/a/ B.B. in the civil litigation against Jeffrey Epstein styled Jeffiey Epstein. case no.: 502008CA037319 MB AB. We are hereby requesting that

0 days to appeal the decision to the Assistant Attorney General of the United States, Alice Fisher. As you recall, you chose to forego an appeal to AAG Fisher, and instead pursued a negotiated resolution which, ultimately, resulted in the execution of the Agreement. The Negotiation Phase During negotiati

.S.C. § 1591(c)(1): Count Date(s) Minor Involved Defendant(s) 2 2001 - 2004 Jane Doe #2 JEFFREY EPSTEIN 3 January 2004 through July 2004 Jane Doe F JEFFREY EPSTEIN SARAH KELLEN 4 July 2004 through December 29, Jane Doe #9 JEFFREY EPSTEIN SARAH KELLEN 38 EFTA00225746 New Jersey to Palm

in the former firm of Herman, Sloman, & Mermelstein, filed five lawsuits, each asking for $50 million, against Mr. Epstein. Each lawsuit is entitled “Jane Doe # vs. Jeffrey Epstein,” despite the fact that each of the plaintiffs is an adult and not entitled to plead anonymously. See Tab 32, Examples of Feder

an threatened to send to an undisclosed list of “victims.” The eventual transmission of this highly misleading letter was only halted by an appeal to AAG Fisher. Among those substantive objections (which related to far more than the “time and place” of the state’s sentencing hearing) were: o Sending the lett

of 188 months. e Facing Ms. Villafana’s threatened draconian indictment, without the claimed offer of the right to raise objections in an appeal to AAG Fisher, the defense chose to negotiate an HOUSE_OVERSIGHT_012176 --- PAGE BREAK --- KIRKLAND & ELLIS LLP Agreement to Defer Prosecution to the State, an