Epstein Secrets

736-KAM Document 416 Entered on FLSD Docket 08/11/2017 Page 23 of 65 So far as appears in the available public materials, Senator Kyl's concern that the Justice Department's policy of conferring with victims about plea agreements before charges were filed would be a "dead letter" went unaddressed. Even today, the Justice

cted with the Justice Department's other statements on combatting sex abuse and trafficking. Attorney General Eric H. Holder Jr. Delivers Remarks at Justice Department Event Marking National Slavery and Human Trafficking Prevention Month (Jan. 29, 2015) http:/Avww.justice.gov/opa/speech/attomey-general-eric-h- holder-jr-

are irrelevant, and we really hope he does not prove the point that a man can commit heinous crimes against children and buy his way out of it. If the Department of Justice's recent commitment to the protection of our children from child molesters is to be more than rhetoric, then this is the time and the case where the

rnment deny that it sent "victim" notification letters to Jane Doe 2, both before it negotiated the NPA and after. See, e.g., DE 407 at 12,11 93-95 (Gov't Resp. to Victims' Statement of Undisputed Facts) (conceding a victim notification letter was sent to Jane Doe 2 in Jan. 2008). As the Court is well awar

remedies also provide a way to insure that those who were responsible for violating their rights are appropriately reviewed for possible sanction by the Justice Department. For example, as the Court knows, the Government has previously declined to investigate the victims' complaint that their rights were violated durin

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

remedies also provide a way to insure that those who were responsible for violating their rights are appropriately reviewed for possible sanction by the Justice Department. For example, as the Court knows, the Government has previously declined to investigate the victims' complaint that their rights were violated durin

es not cite the applicable civil rule is that it has yet to state clearly whether it is willing to abide by the civil rules in this case. See, e.g., Gov't Resp. Mot. Order Not Withhold Evid., DE #59 at 6-7 (refusing to take a position on whether civil rules apply or not). Indeed, the Government has yet to

ines, 951 F.2d 1414 (3d Cir. 1991), explicitly adopts this position. That case concluded that Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived the work-product doctrine as against all other adversaries." Id. at 1429. This holding makes sense, because it is ha

2). Epstein's lawyers, To be sure, as the Government points out, effective defense counsel should always explore plea bargaining opportunities. See Gov't Resp. at 7 (citing Padilla v. Kentucky, 130 S.C.t 1473, 1485 (2010)). But this is a far cry from proving there is a "right" to plea bargaining or that p

at 12, 1 94. In January 2008, Jane Doe 1 met with the line prosecutor and an attorney employed by the Child Exploitation and Obscenity Section of the U.S. Department of Justice. See Gov't Fact. Resp., DE 407 at 13, 1 97. During that meeting, Jane Doe 1 expressed her view that Epstein 9 EFTA00597326 Case 9:08-cv-80736-KA

ims' S.J. Mot."), DE 361 at 7-47 (listing 157 proposed undisputed facts). The Government has responded by contesting some facts, but not others. See Gov't Resp. to 2 EFTA00597319 Case 9:08-cv-80736-KAM Document 417 Entered on FLSD Docket 08/11/2017 Page 3 of 33 Petitioners' Statement of Undisputed Mater