Epstein Secrets

ts production in this case. With regard to item (1) — correspondence with Epstein, the Government withheld the correspondence pending a ruling from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard to the other items, the Government produced 14,825 pages of documents to the

.' As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

ed Mr. Epstein's rights and privileges, Mr. Epstein and his counsel intervened to assert their rights, both in the district court, and on appeal to the Eleventh Circuit. See Doe No. 1, supra. That there would be no judgment against Mr. Epstein at the end of this CVRA litigation, however, was understood throughout t

2006, while the state court charge was pending, Mr. Epstein learned that the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") was investigating whether Mr. Epstein's alleged conduct violated federal law. The USAO- SDFL investigation was led by honorable federal prosecutor

ts production in this case. With regard to item (1) — correspondence with Epstein, the Government withheld the correspondence pending a ruling from the Eleventh Circuit on Epstein's motion to stay production of these materials. With regard to the other items, the Government produced 14,825 pages of documents to the

d.6 As a fourth and final illustration, the victims requested information about why the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL) was "conflicted out" of considering issues relating to the Epstein matter, as well as any information that developed about that conflict after the

s in the context of a criminal sentencing. • All criminal prosecutors in the United States Attorney's Office for the Southern District of Florida (USAO-SDFL) will undergo additional training on the CVRA, victim rights, and victim assistance issues to be completed no later than one year from the date of

intentions, partial rescission would pose a significant risk of harm to certain victims, which must be considered in crafting an equitable remedy. The Eleventh Circuit has admonished courts considering equitable remedies to "bear in mind that a poorly crafted remedy may achieve justice for one by working a substan

to the Illegal Concealment of the Non- Prosecution Agreement 10 2. Evidence Exists that the Epstein Defense Team Acted in Bad Faith. 18 3. The USAO-SDFL Was Not Authorized to Extend Epstein Immunity Without First Conferring with his Victims. 23 II. THE CVRA AUTHORIZES RESCISSION AS A REMEDY.

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that

erences to the "Government" in this case should be generally understood to refer to the U.S. Attorney's Office for the Southern District of Florida (USAO-SDFL), which is currently being represented by the U.S. Attorney's Office for the Northern District of Georgia. 2 EFTA00022550 --- PAGE BREAK --- Ca

. Shore, 439 U.S. 322, 332 (1979). Epstein raises no suggestions that he has been denied that opportunity here. Epstein does point to the fact that the Eleventh Circuit has previously ruled in this case that he is not "an ordinary litigant." Jane Doe 1 v. United States, 749 F.3d 999, 1005 (11th Cir. 2014). But that