Epstein Secrets

ein was taking I consistent position with the State Attorney's Office, Judge McSorley, and the USAO, so I asked for I copy of what was filed in the State Court. This led to multiple letters with counsel for Epstein before I could finalize the victim notification letters (Exhibits B-57 through B-65). On July

o understand that Criminal Chief contacted SLC about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC ma have knowled e of USA Acosta providing my prosecution memorandum to Main Jus

witness, (0 destroying or concealing evidence and (g) maintaining a place for purposes of lewdness and prostitution. In O'Malley, appellants sued in State Court under Florida RICO alleging they were terminated because they refused to participate in alleged RICO violations. O'Malley v. St.. Thomas Univ.. Inc

clear that "Twombly expounded the pleading standard for "'all civil actions'" and not just "pleadings made in the context of an antitrust dispute," Ashcroft v. lqbal, No. 07-1015 (U.S. May 18, 2009) (slip op. at 20) (quoting Fed. R. Civ. P. 1), the need for enforcing these modest pleading requirements i

), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c

ion that all the allegations in the complaint are true (even if doubtful in fact)." Id. The United States Supreme Court very recently made clear in Ashcroft v. lubal No. 07-1015 (U.S. May 18, EFTA00175268 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 3 of 11 Jane Doe II

30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. S

Criminal Chief Matt Menchel contacted SLC Schultz about moving me to Appeals after I pointed out actions that I considered to be in violation of the Ashcroft memo and victims' rights legislation. I also understand that SLC Schultz may have knowledge of USA Acosta providing my prosecution memorandum to Cr

STODIAL SENTENCE ...................................................................... 110 A. June 30, 2008: Epstein Enters His Guilty Pleas in State Court ..........................111 B. Epstein Is Placed on Work Release .....................................................................113 XI.

u know is completely unacceptable to the FBI, ICE [Immigration and Customs Enforcement], the victims, and me. These plea negotiations violate the Ashcroft memo, the U.S. Attorney[s’] Manual, and all of the various iterations of the victims’ rights legislation. Strategically, you have started the plea

was hand written after “6 months” but then crossed out and replaced by “jail sentence.”173 A. June 30, 2008: Epstein Enters His Guilty Pleas in State Court Epstein, with his attorney Jack Goldberger, appeared in Palm Beach County court on June 30, 2008, and entered guilty pleas to the indictment cha

he prosecutor harbors a good faith doubt, based on either the law or the evidence, as to the government’s ability to prove the charge at trial. The Ashcroft Memo explains that the “basic policy” “requires federal prosecutors to charge and pursue all charges that are determined to be readily provable” an