Epstein Secrets

p to any and all information in the government's files." United States v. Rubin, 558 F. Supp. 2d 411, 425 (E D N Y. 2008); see also United States a Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (noting that CVRA did not empower district court in a civil matter to order disclosure of documents to victims);

flect that value. The government regrets that the manner in which it communicated the resolution of the Epstein case to the victims fell short. B. The Department of Justice's commitment to victims of human trafficking and child exploitation supports targeted remedies to give the Epstein victims a voice, an explanation, a

ust be rejected. CONCLUSION Regardless of what the CVRA required the government to do in this matter, the victims are right to expect better from their Justice Department. The government's commitment in the decade since this action was filed to combat human trafficking and child exploitation and protect victims of su

on FLSD Docket 06/24/2019 Page 1 of 3 EXHIBIT 1 EFTA00085741 Case 9:08-cv-80736-KAM Document 462-1 Entered on FLSD Docket 06/24/2019 Page 2 of 3 U.S. Department of Justice United States Attorney Northern District of Georgia 600 us. Caseation IS Ted Tine Dna SW. Admit Genie X1103 May 7, 2019 Paul G. Cassell, . R

ng given that the CVRA was enacted to protect crime victims' rights and ensure their involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007);? II Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime vict

the crimes against the victims; (3) discovery of records explicating why the U.S. Attorney's Office decided to grant Epstein federal immunity; (4) the Department of Justice's designation of a representative to explain the Office's decision to resolve the Epstein case without any federal prosecution; (5) mandatory CVRA t

ice Department's Office of Legal Counsel ("OLCi. Maj. Op. at 1213-14 n.20. The Justice Department's 2010 OLC opinion, like the change of position by the Justice Department's local U.S. Attorney's Office, came only after Epstein's victims filed this lawsuit. See Mohasco Corp. v. Silver, 447 U.S. 807, 825, 100 S. Ct. 2486,

d for disclosure is greater than the need for continued secrecy; and (3) the request is structured to cover only needed materials. United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). 20. Portions of Exhibits 1, 2, an

RANSMISSION OK TX/RX. NO 2683 CONNECTION TEL 6592380 SUBADDRESS CONNECTION ID ST. TIME 09/06 14:62 USAGE T 01'00 PGS. SENT 2 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 400 West Palm Beach, Florida 33401 Facsimile . FACSIMILE CO

counsel upon lift of stay by 11d' Circuit Box #2 P-008364 Thru P-008382 File folder entitled Immunity Request" containing internal memoranda, Justice Department documentation, and subpoena regarding immunity request 6(e) Work Product Deliberative Process Investigative privilege Box #2 P-008383 Thru P

04/07/2011 Page 4 of 9 2007 WL 951666 at *1. Other attempts to engraft discovery rights onto the CVRA have also been rejected. In United States'. Moussaoui, 483 F.3d 220 (4h Cir. 2007), several victims in the September 11, 2001 terrorist attacks sought access to files and records provided by the governm

sed "undisputed material facts" arc in fact disputed and, in many cases, wrong. 'The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the Special Responsibiliti

04/07/2011 Page 4 of 9 2007 WL 951666 at '1. Other attempts to engraft discovery rights onto the CVRA have also been rejected. In United States v. Moussaoui, 483 F.3d 220 (41h Cir. 2007), several victims in the September 11, 2001 terrorist attacks sought access to files and records provided by the govern

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

04/07/2011 Page 4 of 9 2007 WL 951666 at '1. Other attempts to engraft discovery rights onto the CVRA have also been rejected. In United States'. Moussaoui, 483 F.3d 220 (41h Cir. 2007), several victims in the September 11, 2001 terrorist attacks sought access to files and records provided by the govern

sed "undisputed material facts" are in fact disputed and, in many cases, wrong. 2The U.S. Attorney's Office also repeatedly reminded Mr. Cassell of the Justice Department's policy not to comment on the guilt or innocence of an unconvicted person. The ABA's Model Rule of Professional Conduct on the SpecialResponsibilitie

1997); and Pub. L. No. 108-405 (Justice for All Act) (2004). 262 Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006); United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007); and Justice for All Act. 190 Aug 10 FBI begins mterv,ev. mg \'ICtlmS Aug 24 - Villafana e-mail to sup

271 U.S. Dept. of Justice Office of the Inspector General Audit Division Audit Report 08-04, The Department of Justice’s Victim Notification System at 29 (Jan. 2008), available at https://oig.justice.gov/reports/EOUSA/a0804/ final.pdf. The 2008 audit identified concer

he 'right not to be excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department ofJustice ... engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime 14 EFTA00010520 --- PAGE BREAK

0. III. Discussion The CVRA was designed to protect victims' rights and ensure their involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims f

es in responding to crime victims needs; (3) provide "disciplinary sanctions, including suspension or termination from employment, for employees of the Department of Justice who willfully or wantonly fail to comply with provisions of Federal law pertaining to the treatment of crime victims"; and (4) instruct that the "A

p to any and all information in the government's files." United States v. Rubin, 558 F. Supp. 2d 411, 425 (E D N Y. 2008); see also United States a Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (noting that CVRA did not empower district court in a civil matter to order disclosure of documents to victims);

he 'right not to be excluded from any such public court proceeding....' 18 U.S.C. § 3771(a)(2) & (3). Section 3771 also commands that 'employees of the Department ofJustice ... engaged in the detection, investigation, or prosecution of crime shall make their best efforts to see that crime 14 EFTA00027679 --- PAGE BREAK

0. III. Discussion The CVRA was designed to protect victims' rights and ensure their involvement in the criminal justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4th Cir. 2007); Kenna v. U.S. Dist. Court, 435 F.3d 1011, 1016 (9th Cir. 2006) ("The [CVRA] was enacted to make crime victims f