Epstein Secrets

een but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna'. U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpr

would have had, if Mr. Epstein 'The undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -3- EFTA00177302 Case 9:08-cv-; i-KAM Document 14 Entered on FLSD Docket 07/. )8 Page 4 of 21 had been tried federally and

y 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, and his fees were paid by Jeffrey Epstein, the target of the investigation.' 5. In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office

rnment's files"); cf. In re Siler, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming the district court's rejection of victim's argument that the CVRA conferred a gene

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

rnment's files"); cf. In re Siler, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming the district court's rejection of victim's argument that the CVRA conferred a gene

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

een but not heard. The Crime Victims' Rights Act sought to change this by making victims independent participants in the criminal justice process." Kenna'. U.S. Dist. Court for C.D. Cal., 435 F.3d 1011, 1013 (9th Cir. 2006). Accordingly, because the CVRA is remedial legislation, courts should interpr

they were fifteen years old. 2.the undersigned does not know when Mr. Edwards began representing T.M. or whether T.M. ever formally terminated Mr. Eisenberg's representation. -2- EFTA00190507 S. In the summer of 2007, the U.S. Attorney's Office for the Southern District of Florida ("the Office") decid

nment's files"); cf. In re Slier, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming district court's rejection of victim's argument that the CVRA conferred a general

pp. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. a White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09-80199, 2009 WL 1809994, at *3 (S.D. FIa. June 25, 2009)). But that is precisely what Petitioners seek here. Accordingl

rnment's files"); cf. In re Siler, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming the district court's rejection of victim's argument that the CVRA conferred a gene

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

ernment's files"); cl In re Siler, 571 F.3d 604, 609 (6th Cir. 2009) (holding that "the CVRA does not provide an independent right to obtain PSRs"); Kenna v. United States, 453 F.3d 1136, 1137 (9th Cir. 2006) (affirming the district court's rejection of victim's argument that the CVRA conferred a gene

p. 2d 1214, 1216 (S.D. Fla. 2011) (citing Sierra Equity Group, Inc. v. White Oak Equity Partners, LLC, 650 F. Supp. 2d 1213, 1231 (S.D. Fla. 2009); Eisenberg v. Standard Ins. Co., No. 09- 80199, 2009 WL 1809994, at *3 (S.D. Fla. June 25, 2009)). Additionally, declaratory judgment is inappropriate to adjud

rocess; the Act is therefore silent and unconcerned with victims' rights to file civil claims against their assailants." Id. at 234-35, citing In rc Kenna, 453 F.3d 1136, 1137 (9i° Cir. 2006). There is no criminal justice process in the instant case since no criminal charges have been filed. Even if t

the investigation if the facts arc known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

vernment's possession; Coxton (no right 4 EFTA00230167 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR); Kenna (same); and Sacane (no right to financial information from defendant). The CVRA imposes no duty on the U.S. Attorney's Office to provide evidence to

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States v. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States v. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained

on (no right 4 08-80736-CV-MARRA 000921 EFTA00230745 Case 9:08-cv-80736-KAM Document 59 Entered on FLSD Docket 04/07/2011 Page 5 of 9 to PSR); Kenna (same); and Sacane (no right to financial information from defendant). The CVRA imposes no duty on the U.S. Attorney's Office to provide evidence to

the investigation if the facts are known or might attempt to escape if they have reason to believe certain indictments will issue. United States. Eisenberg, 711 F.2d 959, 961 (11th Cir. 1983) (citing United States. Procter & Gamble Co., 356 U.S. 677, 681 n.6 (1958)). Several of the "facts" contained in