Epstein Secrets

2002) (relying on Black's Law Die tionary, in the contexi: of a criminal case, for the definition of ''pending" as ··awaiting decision"); Swartz v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending,'' expressly because '"pendi :1g' is not defined

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida .... " See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Deel. of AUSA Villafana, 07/09/08, ,i 5, attached hereto as Exhibit "A" (emphasis added).

11 EFTA00304752 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 12 of 25 667, 671 (11th Cir. 1998); United States v. Meyers, 32 F.3d 411, 413 (9th Cir. 1994). One such fundamental principle of contract law is that contracts entered into in violation of law are void, and

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

1 1 EFTA00204902 Case 9:08-cv-80736-KAM Document 127 Entered on FLSD Docket 12/05/2011 Page 12 of 25 667, 671 (11th Cir. 1998); United States'. Meyers, 32 F.3d 411, 413 (9th Cir. 1994). One such fundamental principle of contract law is that contracts entered into in violation of law are void, and

orney's Office for violating Jane Doe #1 and Jane Doe #2's rights; • A monetary sanction imposed against the U.S. Attorney's Office, to be paid to Jane Doe #1 and Jane Doe #2 directly or to any other appropriate person or entity;; • An order establishing the precise rule regarding the timing of the obli

ir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swartz v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

nt 38 Entered on FLSD Docket Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Decl. of AUSA ;07/09/08, ¶ 5, attached hereto as Exhibit "A" (emphasis added). Under the A

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swam v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

ered on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . ... See In re. Jane Doe, Case No. 08-80736-CIV-Marrahlohn.son (S.D. Fla.) (DE 14), 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swam v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

red on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). Under the Agreement, the

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swam v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

tted willful acts of child sexual abuse on Jane Doe. These acts resulted in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or emotional health to be significantly impaired. 26. Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had

n August 21, 2008, counsel for the plaintiff called Kathryn Meyers, Esq. of the Lewis Tein law firm to elicit Epstein's position on this motion. Ms. Meyers responded that she would confer with Mr. Tein and call them back. Less than thirty minutes later, however, plaintiff's counsel - - without waiting

REY EPSTEIN and Defendants. EPSTEIN'S RESPONSE TO MOTION TO PRESERVE EVIDENCE [DE 121 Defendant Jeffrey Epstein hereby responds to the plaintiff Jane Doe's motion to preserve evidence, as follows: I. The Certificate of Compliance annexed to the plaintiffs motion states that plaintiff's "counsel confe

Cir. 2002) (relying on Black's Law Dictionary, in the context of a criminal case, for the definition of "pending" as "awaiting decision"); Swam v. Meyers, 204 F.3d 417, 421 (3d Cir. 2000) (relying on Black's Law Dictionary for the definition of "pending," expressly because "'pendi,g' is not defined in

red on FLSD Docket 08/12/2008 Page 3 of 13 "agreed to defer federal prosecution in favor of prosecution by the State of Florida . . .." See In re. Jane Doe, Case No. 08-80736-CIV-Marra/Johnson (S.D. Fla.) (DE 14), Decl. of AUSA Villafana, 07/09/08, 1 5, attached hereto as Exhibit "A" (emphasis added). U

ss it is incriminating and protected by the Amendment or unless protected by one of the evid- entiary privileges," must be dis- closed.' Maness . Meyers, 419 U.S. 449, 473-47444, 95 S.Ct. 584, Page 13 598, 42 L.Ed.2d 574 (1975) (White, 1, concurring in result). Moreover, the constitutional guaran

ney General or any office under his direction.'" Id. at *2 (quoting 18 U.S.C. § 3771(d)(6)). For these reasons, the Court should deny the motion of Jane Doe 1 and Jane Doe 2 to discover and use the plea negotiation letters as evidence. PART II MR. EPSTEIN'S PLEA NEGOTIATIONS ARE PRIVILEGED AND NOT DISCO