Epstein Secrets

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

nces where a contract is clearly divisible." Galaxy Cable, Inc. v. Cablevision of Marion Cty., LLC, No. 5:05-CV-303-OC-GRJ, 2006 WL 2265419, at *3 (M.D. Ha. Aug. 8, 2006). A contract is considered to be "indivisible" when "each and all of its parts appear to be interdependent and common to one another

torney Sloman sent an e-mail to Jay Leflcowitz„ a copy of which is attached hereto as Exhibit _.Bpsteinls—eriminal—defense eeunselr explaining that the Justice Department's Child Exploitation Obscenity Seotion (CEOS) had-agreeil-te-review-Bpstein1/2 -ehjeetiens-te-the--prepese4-plea-agFeement-that-hed-heen-reaehed with

on with the defendant sex offender and. niter he raised objections. slopped making notilleatIons.* Epstein sought 'a higher level of review' within the Department of Justice the motion says. 'A reasonable inference Irons the evidence is that Epstein used his sirlicani pol.lical and social connections to kitty the Justic

terial even if there 'certainly is a public interest in knowing more' about its contents." Tillman'. C.R. Bard, Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Ha. March 13, 2014), 2014 U.S. Dist. LEXIS 41406, at *6, quoting Seattle Times Co.'. Rhinehart, 467 U.S. 20, 31 (1984) Placing limitations on the diss

as Commodities Litig.. 235 F.R.D. 241 (S.D.N.Y. 2006) 2, 8 In re Petroleum Products Antitrust Litig., 680 F.2d 5 (2d Cir. 1982) (per curiam) 18 Lee v. Department of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 Media L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Chri

beyond the power of evidence to controvert them.") (citation omitted). accord Chick-Fil-A, Inc. v. CFT Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09- 15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523, 528-29 (2d Cir. 19

as Commodities Litig.. 235 F.R.D. 241 (S.D.N.Y. 2006) 2, 8 In re Petroleum Products Antitrust Litig., 680 F.2d 5 (2d Cir. 1982) (per curiam) 18 Lee v. Department of Justice 413 F.3d 53 (D.C. Cir. 2005) 2 L.W. ex rel. Whitson v. Knox County Bd. of Educ. 36 Media L. Rep. 1721 (E.D. Tenn. 2008) 5 Medina v. United Chri

beyond the power of evidence to controvert them.") (citation omitted)• accord Chick-Fil-A, Inc. v. CFT Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09- 15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523, 528-29 (2d Cir. 19

1992 (documents received by state agency in course of settlement negotiations to resolve federal lawsuit and confidential settlement agreement with U.S. Department of Justice open to inspection because federal law did not clearly require confidentiality) (Supp.A.-8.) Federal law imposes no such preemption of the Florida

gate suspected crimes without inhibition and engage in unrestricted deliberations." Lockhead Martin Corp... Boeing Co., 393 F. Supp. 2d 1276, 1279 (M.D. Ha. 2005). The rule aims to "prevent disclosure of the way in which information was presented to the grand jury, the specific questions and inquiries