Epstein Secrets

to defer prosecution in favor of prosecution by the State of Florida. Nonetheless, during its investigation, the agents and AUSA, in compliance with the Justice Department's guidelines on working with victims and witnesses, went above and beyond the legal minimum requirements and provided information and assistance prior

in Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the "Motion") [DE 48]. I In the context of a motion alleging that the U.S. Department of Justice violated Plaintiff's rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecif

n should object to the award of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the Department of State. Example 4 to paragraph (0: A Federal Communications Commission (FCC) employee participated in a proceeding to review the renewal of a license for

hts under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of Justice regulations. Movant should be granted leave to intervene to rebut these false allegations, and to seek sanctions. Alternatively, the Court on its ow

f one of its regulations is unsuitable for judicial review, despite the existence of the Administrative Procedures Act ("APA"), like, in this case, the Justice Department's regulations on victim consultations." See id at 831; see also American Disabled for Attendant Programs Today'. United States Dep't of Housing and U

the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson.. Intl Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 08-80736-CV-MARRA 000794 EFTA00230618 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docke

in Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the "Motion") [DE 48]. I In the context of a motion alleging that the U.S. Department of Justice violated Plaintiff's rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecif

n should object to the award of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the Department of State. Example 4 to paragraph (0: A Federal Communications Commission (FCC) employee participated in a proceeding to review the renewal of a license for

hts under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of Justice regulations. Movant should be granted leave to intervene to rebut these false allegations, and to seek sanctions. Alternatively, the Court on its ow

to defer prosecution in favor of prosecution by the State of Florida. Nonetheless, during its investigation, the agents and AUSA, in compliance with the Justice Department's guidelines on working with victims and witnesses, went above and beyond the legal minimum requirements and provided information and assistance prior

f one of its regulations is unsuitable for judicial review, despite the existence of the Administrative Procedures Act ("APA"), like, in this case, the Justice Department's regulations on victim consultations." See id at 831; see also American Disabled for Attendant Programs Today v. United States Dep't of Housing and

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int'l Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00230040 v , Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31

t in Plaintiff's Motion for Finding of Violations of the Crime Victims' Rights Act (the "Motion") [DE 48].I In the context of a motion alleging that the U.S. Department of Justice violated Plaintiff's rights under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecif

hts under the Crime Victims Rights Act, Plaintiffs make irrelevant and gratuitous accusations that Movant violated unspecified Florida Bar rules and Department of Justice regulations. Movant should be granted leave to intervene to rebut these false allegations, and to seek sanctions. Alternatively, the Court on its ow

ed as Exhibit 1 and incorporated by reference). They ultimately allege, "[Movant's] representations [of Epstein's employees] are in contravention of Justice Department regulations and Florida bar rules. Such representations also give, at least, the improper appearance that Reinhart may have attempted to curry [sic]

n should object to the award of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the Department of State. Example 4 to paragraph (0: A Federal Communications Commission (FCC) employee participated in a proceeding to review the renewal of a license for

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205046 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31 DISC

er Clients), and Rule 4-1.11 (Special Conflicts of Interest for Former and Current Government Officers and Employees). For purposes of these rules, the U.S. Department of Justice was Movant's client during his employment in the Office. Movant did not violate any of the bar rules. Rule 4-1.6(a) states: A lawyer shall not rev

ed as Exhibit 1 and incorporated by reference). They ultimately allege, "[Movant's] representations [of Epstein's employees] are in contravention of Justice Department regulations and Florida bar rules. Such representations also give, at least, the improper appearance that Reinhart may have attempted to curry [sic]

n should object to the award of the contract, she is directing her communication to a Department of State employee in his capacity as an employee of the Department of State. Example 4 to paragraph (0: A Federal Communications Commission (FCC) employee participated in a proceeding to review the renewal of a license for

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (11th Cir. 2007). 3 EFTA00205077 Case 9:08-cv-80736-KAM Document 79-1 Entered on FLSD Docket 05/03/2011 Page 5 of 31 DISC

eedings free from unreasonable delay. (8) The right to be treated with fairness and with respect for the victim's dignity and privacy. Members of the U.S. Departinent of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these protec

e Justice Department stopped making victim notifications because of U.S. Attorney's Conespondence at 270 (emphasis added). It was a deviation from the Justice Department's standard practice to negotiate with defense counsel about the extent of crime victim notifications. 30. The December 13, 2007, letter also demonstr

hey do not cite to any particular bar rule or regulation that they believe was violated. They do not explain how the alleged conduct contributed to the Department of Justice's alleged violation of the CVRA. Nor do they explain how the alleged conduct is imputable to the Department of Justice. These otherwise slanderous ac

he attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson v. Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). EFTA00230005 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD Docket 05/03/2011 Page 5 of 31 D

s free from unreasonable delay. (8) The right to be treated with fairness and with respect for the victim's dignity and privacy li • Members of the U.S. Department of Justice and other federal investigative agencies, including the Federal Bureau of Investigation, must use their best efforts to make sure that these rights

e Justice Department stopped making victim notifications because of U.S. Attorney's Conespondence at 270 (emphasis added). It was a deviation from the Justice Department's standard practice to negotiate with defense counsel about the extent of crime victim notifications. 30. The December 13, 2007, letter also demonstr

hey do not cite to any particular bar rule or regulation that they believe was violated. They do not explain how the alleged conduct contributed to the Department of Justice's alleged violation of the CVRA. Nor do they explain how the alleged conduct is imputable to the Department of Justice. These otherwise slanderous ac

the attorney's subjective intentions, the conduct was unreasonable and vexatious when measured against an objective standard." Hudson' Int 1 Comp. Negotiations, Inc., 499 F.3d 1252, 1262 (111h Cir. 2007). 3 08-80736-CV-MARRA 000759 EFTA00230583 • • • Case 9:08-cv-80736-KAM Document 79.1 Entered on FLSD Doc